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Limit on cash payments from clients
Monday 06 June 2011
I act for a buyer in a domestic conveyancing matter and my client has come into the office with £20,000 cash to pay his deposit. Upon questioning the client it appears the money is from his own account but he did not want to pay the £30 bank fee for a bank cheque and hence the cash. Is there a limit upon the amount of cash firms can accept from clients?
Large Payments made in actual cash may be a sign of money laundering.
Although the Law Society has not set a cash limit, the Law Society advises that as a matter of good practice you establish a policy on not accepting cash payments above a certain limit either at your office or into your bank account.
The Law Society has steered clear of setting limits because cash tolerance will be different for every firm depending on the type of work done. Please see Chapter 11 of the Law Society’s Anti-Money Laundering (AML) Practice Note (PN) 2007.
Chapter 11 of the Law Society's Practice Note on Anti-Money Laundering looks at the importance for solicitors to look for warning signs.
It is a matter for you when considering all the information at your disposal, whether you feel you have reasonable grounds for suspicion or knowledge of money laundering.
Cash in itself is legal tender and should not necessitate an automatic report to the Serious Organised Crime Agency (SOCA) but depending on the circumstances you may need to undertake further checks and customer due diligence for example, by asking for evidence to support the statement provided, in order to satisfy yourself that there are no grounds for making a report to SOCA.
Just because money comes from a bank account does not in itself indicate that the funds are clean.
You can view the AML Practice Note here.
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