Legal
Responsible sourcing and anti-money-laundering
We only want to buy metal that belongs to the person selling it. Here are the checks that follow from that, the law behind each one, and what happens when something does not add up.
1. How we pay, and why it matters
- 1.1Payment is by bank transfer to a United Kingdom account in the seller's own name. We do not handle cash in either direction. Under the Money Laundering Regulations, a business that accepts or makes cash payments of €10,000 or more must register with HMRC as a high value dealer; because no cash moves through this business, our payment method does not trigger that registration.
2. What we are not registered for, and what still applies
- 2.1We are not registered with HMRC as a high value dealer, we are not supervised by anybody for money laundering, and we are not regulated by the Financial Conduct Authority. We will never say otherwise, and if you see any of those claims made about us anywhere, they are wrong. The high value dealer regime turns on cash; we take none, so it does not apply. Buying second-hand precious metal is not a regulated financial activity, so no financial-services protection attaches to a sale to us.
- 2.2What is not switched off by any of that is the Proceeds of Crime Act 2002. Its principal offences — concealing criminal property, entering into an arrangement about it, and acquiring or possessing it — apply to every business in the country, supervised or not. So the checks on this page are not a formality performed by somebody who has to: they are how we keep ourselves out of those offences, which is a stronger reason for doing them properly than a supervisor would be.
- 2.3The reporting duty that falls on the regulated sector — the obligation to file a suspicious activity report or commit an offence by not doing so — does not fall on us. We can still make a report to the National Crime Agency voluntarily, and where we suspect an item is the proceeds of crime we will. A disclosure of that kind can also protect a transaction that would otherwise be an offence. We say all this because a seller is entitled to know that a report about their parcel would be one we chose to make.
3. Scrap metal licensing
- 3.1The Scrap Metal Dealers Act 2013 leaves gold, silver and alloys containing 2 per cent or more of either out of its definition of scrap metal, so its licensing regime does not reach our precious-metal purchases. Where an item turns out to be base metal rather than the alloy it was described as, we do not buy it at all.
4. When we ask who you are
- 4.1Before the first payment to any seller we ask for a photograph of one government-issued photo identity document, and we check the name on it against the bank account and the pack request.
- 4.2Inherited and estate items need something showing you are entitled to sell them — a grant of probate, letters of administration, or a letter from the executor. If you are selling on somebody else's behalf we need written authority from the owner and the owner's identity as well as your own.
- 4.3An unusually large consignment, or a run of consignments from the same seller, prompts a short conversation about where the items came from. It is not an accusation and it is not a test with a right answer; it is the question a buyer is expected to ask.
- 4.4Identity documents are stored apart from the case file with access logged, and deleted on the schedule in the privacy notice.
5. If we think an item is stolen
- 5.1What starts a hold. Reasonable grounds to suspect that an item is stolen, and nothing less. In practice that means an engraving or inscription that does not match the seller and is not explained, an item that appears on a stolen-goods register, a piece whose account of itself does not fit the piece, or a report from the police or an owner about something we have. A suspicion is not a finding, and a hold is not an accusation.
- 5.2What happens to the item. It is set aside whole. It is not paid for, not priced, not tested further, not melted and not sent anywhere. It is photographed as it is, stored separately from other sellers' property and logged. Nothing about it becomes irreversible while the question is open.
- 5.3When you are told. Promptly, and in writing: what is being held, which of the triggers above applied, what we have done and what happens next. The only exception is where telling you would itself be unlawful, or the police have asked us not to. In that case we say nothing rather than say something misleading, and we tell you as soon as we are permitted to. We do not use silence as a way of managing an awkward conversation.
- 5.4What ends a hold. Any of four things. You produce something that explains the piece — a receipt, an insurance schedule, a valuation, a probate inventory, a photograph of a relative wearing it. The register entry or report turns out not to match. The police tell us they have no interest in it. Or we conclude on the material in front of us that the suspicion was not made out. When a hold ends and you still want to sell, the offer process picks up where it stopped; when it ends and you would rather have the item back, it is posted to you tracked, at our cost, the same way a declined lot is.
- 5.5How long it can last. Not indefinitely. We review a hold at least every 28 days and write to you at each review with where it stands, even if the answer is that nothing has changed. Where the police have taken over the question, the item may be with them or subject to their instructions and the timing stops being ours — we tell you that plainly, and we tell you who to ask. What we will not do is keep something quietly because a file was never closed.
- 5.6How you challenge it. Reply with whatever you have; there is no form and no fee. A hold is reviewed under the complaints process by somebody who did not impose it, and you will get the reasons in writing. If you think we are wrong and we still will not release the item, you can take it to court like any other dispute about property, and we will say in writing what we hold and why so that you are not arguing with a blank. The rest of your lot is never held hostage to one piece: anything not affected is offered on or returned as usual.
- 5.7A record of the suspicion and of what we did about it is data about a suspected criminal offence, which data protection law treats separately from everything else we hold. Section 8 of the privacy notice says on what basis we keep it, for how long and what you can ask about it.
6. When we decline to buy
- 6.1We can decline any item or any parcel, and we do not have to give a commercial reason. In practice we decline where identity or entitlement cannot be established, where the account of an item does not hold together, where a piece contains restricted material, or where buying it would put us on the wrong side of sanctions or proceeds-of-crime law.
- 6.2Declining is not the same as holding. Unless the police have asked us to hold something, anything we will not buy is listed, left out of the offer and posted back to you tracked and signed for, at our cost, on the terms set out in the terms of service.
7. Restricted materials
- 7.1The Ivory Act 2018 banned dealing in elephant ivory from 6 June 2022, and from 28 January 2025 the ban also covers hippopotamus, killer whale, narwhal and sperm whale ivory. Narrow exemptions survive, including registered pre-1947 items with less than 10 per cent ivory by volume, all of it integral to the item, but they carry registration and fees.
- 7.2We do not buy any piece with ivory in it, registered as exempt or not, and we do not keep it: it comes back to you whole, with the ivory still attached, alongside anything else you have declined. Silver teapots and coffee pots often have ivory heat insulators. Please send photographs of a piece like that rather than posting it. If one arrives anyway, nothing is removed from it: it is looked at as it stands, and the written assessment names the piece and says why it could not be bought.
- 7.3We do not carry out certified identification of materials. Where a handle, insulator, finial or inlay might be ivory and cannot be told from bone or an imitation by looking, we treat it as ivory under clause 7.2 and send the piece back whole rather than guess. Whether a piece qualifies for an exemption is for its owner to establish with GOV.UK; the ivory guide explains the exemptions and where to register.
8. Hallmarking
- 8.1Where an article is resold whole rather than refined, the Hallmarking Act 1973 governs how it may be described, and a dealer supplying such articles must display the statutory dealer's notice explaining the approved hallmarks. Ours will be displayed wherever articles are supplied to the public, once that is settled.
9. What we write down
- 9.1Every purchase carries its item report, the outcome of the identity check, the payment reference and the name of the person who handled it, and that record is kept for the periods set out in section 3 of the privacy notice. The procedure on this page is the procedure: it is not a summary of a longer internal document that says something else, and if the two ever diverge this page is the one we are bound by.
- 9.2None of this is an accreditation and none of it is approval by anybody. It is what the law requires of a buyer of second-hand precious metal, written down so you can see we know what it is.