The money laundering regulations for small businesses that are also potentially high value dealers are exceptionally onerous, and in many cases nonsensical. The paperwork trail is excessive for small business and is taking up far too much time, particularly when combined with all the other regulations (and inspections) that we must endure.
At the very least, increase the sum at which checks must be made to 50K and take the smaller companies out of the process. We know our trade, and are capable (and adept) at spotting dodgy customers without needing to keep vast reams of paperwork to confirm the fact.
Why does this idea matter?
The whole process is, for us, a waste of time and effort.
We are a small exporter that occasionally has to accept cash from foreign customers. We deal in large metal objects such as trucks that are highly unlikely to form a basis for any money laundering activities and can't easily be smuggled across borders, and are about to face a third inspection in 5 years, at I suspect significant cost to the government.
Each inspection brings a list of requirements and infringements that are simply impossible or impractical to achieve, as these regulations are designed for companies operating wholly within the UK and with access to information held within the UK. We are asked to follow a paper exercise that has little to do with real life. We have been warned, after taking copies of passports, that we have accepted cash after the passport has subsequently expired (what, do people cease to exist until they renew?), that we have not taken a passport for a customer that we have dealt with for 35 years and visited abroad in his place of work, that we need to confirm the source of money by filling in a form to confirm that we have asked the question (because, if the money is dodgy, the customer is clearly going to say so)…and so on. We did not apparently "have a form on which members of staff can report their suspicions" although we area company of 6 people with desks less than 10 metres apart. We cannot rely on a formal trade reference and export guarantee from Atradius, under a scheme which was originally run on behalf of the DTI, to confirm an identity even though this process requires a visit in the customer's land, but instead need a "copy of a passport or a faxed letterhead". We have formal shipping documents specifying address etc for all of the goods, confirmed through customs in the destination country – why on earth is this not good enough?
And frankly, for our type of business, who is going to bother laundering only 15,000 euros? Surely, the time and effort of inspections would be better directed to the larger sums?
And who hasn't got annoyed when a bank or business that you have been dealing with for 40 years asks for copies of your passport to confirm that you are, in fact, who they know you have been for years and years. And, when you have five companies in a group, have to supply the information five separate times, once for each of the companies concerned….
Common sense, please…