Obliged entity
Diamond dealer
Registered diamond dealers are fully obliged entities, whatever the amount of the sale and whatever the means of payment.
Here, the obligation
is read off the invoice.
In high-value goods trading, the law does not look at your trade but at what you sell, for how much and by which means you are paid. AML Company places every sale against those thresholds before asking you for anything.
Check a professional buyer
Thresholds computedBuyer identifiedCash ceilingAudit trail
Applicable thresholds
Sale in progress · lot of antiques
DiamondsNo threshold
Fully an obliged entity
Art and antiques≥ €10,000
Obliged from the threshold on
Cash payment€3,000 max
Statutory ceiling, every dealer
Amount of the sale
14 500 €
Payment offered
€2,000 in cash, the balance by transfer
VerdictSale within the scope
Does this concern you?
Three situations, three different answers
“High-value goods trading” covers regimes that have almost nothing in common. Start by identifying yours: everything else follows from it.
Depends on the amount
Art or antiques dealer
The obligation applies to sales of works of art or antiques of at least €10,000, whether the sale happens at once or through linked transactions.
Cash ceiling
Other dealers
The cash payment ceiling applies without making the dealer an obliged entity. It is a payment ban, not a diligence regime.
The ceiling of article 67, §2
€3,000,
and not one euro more in cash.
The ceiling targets the payment, not the client. It applies whatever the goods sold, is computed on the whole transaction and cannot be worked around by splitting the invoice.
Accepted
A cash payment up to the ceiling, the balance settled by a traceable means, on one and the same invoice.
Refused
A payment made entirely in cash above the ceiling, or an invoice split in two to stay under the bar.
The ceiling is a payment rule: exceeding it is an offence in itself, independently of any suspicion of money laundering.
Proportionate diligence
The goods do not tell the whole story,
and neither does the buyer.
Once the sale falls within the scope, the intensity is computed on the buyer, the amount and the means of payment.
Ordinary sale
Low- Identified resident buyer
- Traceable bank payment
- Amount consistent with the goods
Diligence
Simplified diligence
Sale to watch
Medium- Buyer acting on behalf of a third party
- Delivery or shipment abroad
- Sales close together to the same buyer
Diligence
Standard diligence
Sensitive sale
High- Politically exposed (PEP) or sanctioned buyer
- Split payment or payment made by a third party
- Price unrelated to the value of the goods
Diligence
Enhanced due diligence (EDD)
Platform
Compliance,
without leaving the counter.
A dealer has no compliance department. Every module fits inside the time of a sale.
Threshold computed on the sale
The type of goods, the amount and the means of payment determine whether the sale falls within the scope, and the answer stays attached to the sale.
€10,000€3,000 in cashDecision on record
Professional buyer
When the buyer is a company, its CBE record (legal form, registered office, directors, activity) feeds the file with no retyping.
CBEVAT · NACE
Ultimate beneficial owners
Behind a buying company, the ownership chain unfolds and is reconciled with the UBO register.
UBO registerOwnership chain
Sanctions and PEPs
The buyer is screened against the sanctions lists and politically exposed statuses before the goods are handed over.
SanctionsPEP
Linked transactions
Sales close together to the same buyer are grouped, so that the threshold is read on the real transaction and not on the invoice.
GroupingSplitting detected
Register of the sales concerned
The sales that fall within the scope form a dated register, exportable with its supporting documents on the day of an inspection.
RegisterPDF exportArchive
A beautiful object asks no questions. Its buyer does.
High-value trading is sought after because it concentrates a lot of money in very little volume. AML Company documents what you checked before letting the goods go.
What the law expects
Your duties,
as soon as the sale falls within the scope.
Below the threshold, nothing applies. Above it, it is the full diligence baseline. AML Company triggers it on the sale concerned, and not before.
Legal basis: art. 5, §1, 31° and 31°/1 of the Act of 18 September 2017
Scope: Diamond dealers are fully obliged entities (31°). Buyers, sellers and intermediaries in works of art or movable goods over 50 years old are, when the listed price is at least €10,000 (31°/1). For other dealers, the cash payment ceiling (€3,000, art. 67 §2) applies without making them obliged entities.
General information based on the Belgian framework; it is not legal advice.
- Identification and verification of the client's identity (KYC)
- Identification of the ultimate beneficial owners (UBO register)
- Assessment of money-laundering and terrorist-financing risks
- Ongoing diligence and monitoring of transactions
- Reporting suspicions to the CTIF
- Retention of the documents and appointment of an AMLCO
Frequently asked questions
High-value trading
and anti-money laundering.
Is high-value goods trading covered by AML law?
It depends on the goods sold. Registered diamond dealers are fully obliged entities (art. 5, §1, 31° of the Act of 18 September 2017). Dealers in works of art and antiques are, for sales of at least €10,000. Other dealers do not become obliged entities on that ground alone.
What does the €3,000 cash ceiling change?
It is a payment ban, not a diligence regime: it binds every dealer without making them obliged entities. Exceeding the ceiling is an offence in itself (art. 67, §2).
Is the €10,000 threshold computed per invoice?
It is computed on the transaction, including when it is carried out in several payments or in several clearly linked sales. Splitting a sale to stay under the threshold does not take it out of the scope.
Must every buyer be identified?
Only for the sales that fall within the scope. That is why the platform starts by qualifying the sale: it also documents the ones where you had nothing to do.
Get started
Know where you stand.
Then prove it.
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