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Responsible sourcing and anti-money-laundering

We only want to buy metal that belongs to the seller, or that the seller is authorised to sell. 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. 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 ten thousand pounds or more for goods (10,000 euros before 30 June 2026) must register with HMRC as a high value dealer. No cash moves through this business, so that registration does not apply to us. None of this puts a limit on what you can sell: the guide to what gets reported when you sell gold sets out the rules that do apply to a seller.

Source: the Money Laundering Regulations 2017, regulation 14, as amended by regulation 9 of the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 (S.I. 2026/621), in force 30 June 2026, on legislation.gov.uk; and GOV.UK, Money laundering regulations: high value dealer registration, which still gave the euro figure; both accessed 26 September 2026.

2. What we are not registered for, and what still applies

  1. 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 are not an assay office and have no connection with any UK assay office. 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. 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, using or possessing it) apply to every business in the country, supervised or not. So we carry out the checks on this page properly, because that law applies to us whether or not anyone supervises us.
  3. 2.3The reporting duty that falls on the regulated sector, where failing to report a suspicion is itself an offence, 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. You are entitled to know that a report about a parcel would be one we chose to make.

Source: HMRC, Money laundering supervision for high value dealers (ECSH51525), and the Proceeds of Crime Act 2002, sections 327 to 329 and 338, accessed 19 September 2026.

3. Scrap metal licensing

  1. 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 purchases of gold and silver. Platinum and palladium are not named in that exclusion, so whether buying broken platinum and palladium needs a scrap metal dealer's licence is being checked with the local authority. Where an item turns out to be base metal rather than the alloy it was described as, we do not buy it at all.

Source: legislation.gov.uk, Scrap Metal Dealers Act 2013, section 21, accessed 7 September 2026.

4. When we ask who you are

  1. 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 name on the bank account and on your request.
  2. 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.
  3. 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. 4.4Identity documents sent through this website, once the forms are switched on, are stored apart from the case file with every opening logged. Documents sent by WhatsApp or email are downloaded to that store and deleted from the message thread once the store is in use. All are deleted on the schedule in the privacy notice.

5. If we think an item is stolen

  1. 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 we find listed on a stolen-property 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.
  2. 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.
  3. 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.
  4. 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 and signed for, at our cost, the same way a declined lot is.
  5. 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.
  6. 5.6How you challenge it. Reply with whatever you have; there is no form and no fee. To reach us, ring, text or WhatsApp 07369 296063, or write to Unit 172, 14-15 Triangle South, Clifton, Bristol, BS8 1EY, or email messinabenni@gmail.com. Assaypost is run by one person, so there is nobody else inside the business to review a hold. On request the decision is looked at again under the complaints process and explained to you in writing, and you may take it to the routes outside the business that the complaints page names. 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 you know exactly what you are challenging. One held piece never holds up the rest of your lot: anything not affected is offered on or returned as usual.
  7. 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

  1. 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.
  2. 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

  1. 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.
  2. 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 item list names the piece and says why it could not be bought.
  3. 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.

Source: GOV.UK, Deal in items made of or containing ivory, accessed 7 September 2026.

8. Hallmarking

  1. 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. If we supply articles to the public, we will display the notice wherever we do so.

Source: GOV.UK, Hallmarking: how businesses can comply with the law, accessed 7 September 2026.

9. What we write down

  1. 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. This page is our full procedure. There is no separate internal version, and if one ever existed and said something different, this page is the one we are bound by.
  2. 9.2None of this is an accreditation and none of it is approval by anybody. It is how we keep within the law that applies to a buyer of second-hand precious metal, written down so you can see what we do.

Version 0.4.4 · 1 October 2026 · Next review by 1 October 2027, or sooner if the law or the procedure changes · Drafted in-house from the sources cited above; legal review pending. See also the identity and provenance guide and the terms of service.

  • 0.4.4, 1 October 2026. Clause 5.6 promised that a hold would be reviewed by somebody who did not impose it. Assaypost is run by one person, so that could not be done; the clause now says what will be done instead: the decision is looked at again on request, explained in writing, and can be taken to the outside routes on the complaints page. Clause 3.1 said the Scrap Metal Dealers Act does not reach our precious-metal purchases; the Act's exclusion names gold and silver only, so the clause now says that and that the position on platinum and palladium is being checked. Clause 4.4 now says how an identity document is stored whichever way it is sent. Clause 5.4 now says a released item comes back tracked and signed for, as clause 6.2 and the terms already said.
  • 0.4.3, 1 October 2026. Wording only; nothing we check, hold or owe you has changed. Clause 9.2 said this page is what the law requires; no registration or supervision regime requires these checks of us (section 2 explains why), so it now says they are how we keep within the law that does apply. Clause 2.1 now says we are not an assay office and have no connection with one. Clause 5.1 now refers to a register we find an item listed on, rather than implying every item is checked against one. Clause 5.6 now gives our telephone and postal address for a challenge. Clause 8.1 no longer carries an internal note. Clause 7.2 calls the record an item list rather than an assessment. Plain-English and punctuation changes to the opening, 1.1, 2.2, 2.3, 4.1, 4.2, 5.4, 5.5, 5.6 and 9.1, and to the 0.3 entry below.
  • 0.4.2, 26 September 2026. Clause 1.1 gave the high value dealer cash threshold as 10,000 euros. Regulation 9 of the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 replaced it with ten thousand pounds from 30 June 2026, so the clause now gives the figure in pounds, notes the old one, and cites the amending regulation. What we do has not changed: we take no cash, so the registration still does not apply. Clause 1.1 also links to the guide on what gets reported when you sell gold.
  • 0.4.1, 21 September 2026. Clause 9.1 said the purchase record is kept for “the accounting period”, which could be read as a single year; it now points to the periods in the privacy notice. Clause 7.1 now gives the third condition of the low-content ivory exemption, that all of the ivory is integral to the item.
  • 0.4, 21 September 2026. Clause 7.2 made unconditional: a piece with ivory in it is not bought at all, registered or not, and comes back whole. The earlier wording could be read as buying the silver and returning the ivory, which is not what happens. Sellers are now asked to send photographs of such a piece rather than post it. Clause 7.3 added: material that might be ivory is treated as ivory.
  • 0.3, 19 September 2026. New section 2: this business holds no money-laundering registration, is supervised by nobody, is not a regulated financial business, and the Proceeds of Crime Act applies to it anyway. Section 5 turned from a two-sentence right to withhold into a published procedure with triggers, what happens to the item, when you are told, what ends a hold, a 28-day review and a route to challenge it. Clause 5.7 added, pointing at the data-protection basis for the record. A statement that the procedure is “reviewed each year” removed; this page is the procedure.
  • 0.2, 19 September 2026. First version to carry a version line. Every legal proposition sourced to a primary source with the date it was checked.