The sniff test


The relationship between jewellers and the AML regime is a complicated one.  For several years most jurisdictions have recognised the concept of the “high value dealer” – under UK legislation, that’s “a firm or sole trader who by way of business trades in goods (including an auctioneer dealing in goods), when the trader makes or receives, in respect of any transaction, a payment or payments in cash of at least 10,000 euros in total, whether the transaction is executed in a single operation or in several operations which appear to be linked”.  But the Fifth Money Laundering Directive has extended the AML family (regardless of method of payment) only to bring in “art market participants” – and this does not, for the most part, encompass jewellers.  In short, jewellers are in only if they accept large amounts of cash.  And boy oh boy, do Trotters Jewellers of Bethnal Green accept large amounts of cash.

Did you see it?  Did you watch the Channel 4 documentary called “Diamond Dealers and Cockney Geezers”?  If not, you have a fortnight left to watch it on catch-up – go and feast your eyes.  If bling’s your thing, Judd, Kallum and Alex are the chaps for you.  You may even be tempted by “the chandelier” – a normal watch sent to Hong Kong to be plastered with 100 carats of diamonds and then priced at £100,000.  For my part, I was drawn in by the artfully angled shots of their cash-counting machine, and – with this visible evidence of their HVD status – I looked forward to a detailed explanation of their CDD procedures and source of funds enquiries.

I can report that this seems to consist mainly of asking customers, “What do you do, then?” as the customer hoicks great wads of cash from their holdall (or even from a McDonald’s bag, apparently).  One such customer, Radley, explained that he’s a brickie and was buying himself a £12,000 watch as a reward for “grafting my arse off” (And only, I am sure, after paying the required tax on his earnings.)  Of course, CDD does not make riveting viewing for most people and perhaps the trio were doing more behind the scenes, but as they boasted of their customers being “city boys, gangsters, travellers and local crackers” – as well as “local amateur horticulturist” Grizz – perhaps not.  None of the lads admitted to being the MLRO.  And as for source of funds, they observed that “you can tell where the money’s from by smelling it – if it stinks of weed, well, that’s standard”.  I assume this documentary is required viewing at HMRC…