A cash transaction record logs a large payment an obliged business must scrutinise. The Money Laundering Regulations 2017 treat a dealer in goods as a high value dealer at €10,000 of cash. That threshold counts one payment or several linked ones. MLR 2017 reg 27 sets when due diligence is due, including an occasional transaction of €15,000 or more. anonym.plus removes the customer's name, identifier, and account from an internal copy on your device.
When this applies
HMRC supervises high value dealers and money service businesses under MLR 2017. A team often coaches new staff with a past form. That teaching copy needs the threshold and the date, not the customer. You clean it and leave the retained record untouched.
How anonym.plus handles it
- Open the teaching copy in anonym.plus on your device.
- Local OCR reads a scanned deposit slip if one is attached.
- The tool flags the name, NINO, and account number.
- Keep the amount and date for the lesson.
- Swap each identifier for a label.
- Save the clean copy locally.
What you need to provide
- The internal copy of the report (PDF, DOCX, or scan).
- An operator (Replace keeps the figures readable).
- Optional allow-list for the threshold amount.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Dan Pruitt → [CUSTOMER] |
| Identifiers | UK_NINO | QQ 50 98 22 B → [NINO] |
| Financial | UK_SORT_CODE | 09-14-42 → [SORT_CODE] |
| Money | MONEY | £12,500 cash → [AMOUNT] |
| Contact | PHONE_NUMBER | +44 161 555 4410 → [PHONE] |
| Location | LOCATION | 44 Elm Street, Leeds → [ADDRESS] |
Compliance achieved
- MLR 2017 reg 27 sets when due diligence is due, including an occasional transaction of €15,000 or more.
- A dealer in goods becomes a high value dealer under MLR 2017 at €10,000 of cash, single or linked.
- MLR 2017 reg 40 keeps the retained record, with full identifiers, for five years.
- A cleaned teaching copy supports the staff training MLR 2017 reg 24 requires.
- Data minimisation under UK GDPR Art. 5(1)(c) favours a copy carrying only the fields the lesson needs.
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Limitations & cautions
The retained record must carry full identifiers to meet MLR 2017 reg 40. Redact only review or training copies. A cleaned sum tied to one date can still narrow down a customer, so weigh what you keep.
Frequently asked questions
May I redact the record before I retain it?
No. Reg 40 expects the retained record to hold full identifiers for five years. Clean only an internal copy used to teach or review threshold handling.
Which cash threshold applies to my business?
MLR 2017 treats a dealer in goods as a high value dealer at €10,000 of cash, counting linked payments together. Reg 27 separately requires due diligence on an occasional transaction of €15,000 or more.
Does anything go to the cloud?
No. The desktop app runs locally, so the form and its data never leave your device.