The FCA(Financial Conduct Authority) in the UK requires banks to have "adequate policies and procedures sufficient to counter the risk that they might be used to further financial crime".

There is no specific limit on cash receipts imposed by the FCA, and the attitude of the banks will depend on their prior knowledge of you. The algorithms that identify retail depositor behaviour may trigger the banks anti-money-laundering mechanisms to inquire further, should there be a concern of an abnormal activity in depositing.

Consider the following scenario: An individual that routinely pays in steady and low income into the account (suppose 1000GBP a month), decides to sell their belongings for cash and deposits e.g. 25,000 GBP. This is flagged by their bank as suspicious activity. I have 3 questions:

  1. Can this be classified as Unexplained Wealth, if the depositor is unable to prove the origin of funds?

  2. If this cannot fall under the Unexplained Wealth Order(UWO) see description below, then can the funds be confiscated?

  3. If the individual is refused in depositing cash by the bank, what role does the FCA play in this process? Is the individual able to take their cash and attempt depositing to another bank?

Quote by UK Home Office:

A UWO requires a person who is reasonably suspected of involvement in, or of being connected to a person involved in, serious crime to explain the nature and extent of their interest in particular property, and to explain how the property was obtained, where there are reasonable grounds to suspect that the respondent’s known lawfully obtained income would be insufficient to allow the respondent to obtain the property. The test for involvement with serious crime is by reference to Part 1 of the Serious Crime Act 2007.

A UWO can also be applied to politicians or officials from outside the European Economic Area (EEA), or those associated with them i.e. Politically Exposed Persons (PEPs). A UWO made in relation to a non-EEA PEP would not require suspicion of serious criminality.

PS. I would be keen to hear about similar practices in the US and EU.

  • 1
    Do you have any documentation of your sale? 25,000 GBP is a lot for a "yard sale", and things like selling your car are well documented (with a signed contract, the name of the buyer, the age and model of car give a good appraisal of its value...) – SJuan76 Feb 25 '18 at 0:55
  • @SJuan76 It is irrelevant what the sum is as there is no set threshold for flagging suspicious activity, as I highlighted above. So your 2008 vintage iPod sale for 500 bucks technically might be flagged, which in general tends to be in shortage of receipts or contracts... – Badalyan Feb 26 '18 at 10:39

In what way is this person "reasonably suspected of involvement in, or of being connected to a person involved in, serious crime": having cash is not enough to create a reasonable suspicion of this. So, no.

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