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In the United Kingdom (UK), the Financial Conduct Authority (FCA) requires that banks 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 (AML) mechanisms to inquire further, should there be a concern of an abnormal activity in depositing.

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

  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's cash deposit is refused by the bank, what role does the FCA play in this process? Is the individual able to take their cash and attempt to deposit it at another bank?

Quote by the 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.

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    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, 2018 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, 2018 at 10:39

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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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