# AMLR Art. 80 — Large-cash-payment limit > GwG Art. 8a's CHF 100 000 threshold applies; since 1 October 2026 a CHF 15 000 threshold applies to precious metals and stones (new Art. 8a Abs. 2bis, inserted by the TJPG amending annex). AMLR Art. 80 applies from 10 July 2027. See [[Effective-dates timeline]]. - **Part of:** [[AMLR]] - **FATF keying:** _none_ - **Swiss provisions:** _none with the same function_ — Switzerland has no cash-payment limit. Related: [[GwG Art. 8a - Due diligence for dealers (cash|GwG Art. 8a]], a due-diligence trigger for dealers, not a limit (see *Key divergences*). - **Detailed citation:** - > [!tip] In practice > - Switzerland has no cash-payment limit. Dealers must apply due diligence above CHF 100 000 in cash, or CHF 15 000 for precious metals and stones (GwG Art. 8a). > - From 10 July 2027 the AMLR prohibits cash payments above EUR 10 000 for goods or services. > - The thresholds are given in their own currencies. This note does not convert them. ## What it requires AMLR Art. 80(1) caps cash payments for goods or services at EUR 10 000 (or the equivalent), single or linked operations. Member States may set lower limits (Art. 80(2)); existing lower national limits continue (Art. 80(3)). Exempt: payments between non-professional natural persons, and payments/deposits at credit institutions, e-money issuers and payment service providers, though those above the limit must be reported to the FIU (Art. 80(4)). Member States must penalise professional breaches (Art. 80(5)-(6)) and may suspend the limit for force-majeure loss of non-cash payment means (Art. 80(7)). ## Swiss position Switzerland sets no ceiling on cash payments. GwG Art. 8a instead triggers due-diligence duties for goods dealers (Art. 2 Abs. 1 Bst. b) accepting more than CHF 100 000 in cash in one trading transaction, including split tranches together exceeding that sum (Art. 8a Abs. 1, 3): identifying the contracting party (Art. 3 Abs. 1), establishing the beneficial owner (Art. 4 Abs. 1, 2 Bst. a-b), documentation (Art. 7), and clarifying background where the transaction looks suspicious (Art. 8a Abs. 2). Until 30 September 2026 the duty fell away if the excess was routed through a financial intermediary (old Art. 8a Abs. 4). Since 1 October 2026 the TJPG annex adds a CHF 15 000 threshold for precious-metal or precious-stone trading (Abs. 2bis; bank-precious-metal dealers excluded, Abs. 2ter) and replaces Abs. 4 with a rule extending the duties to real-estate dealers taking cash, so that carve-out is gone. ## Key divergences AMLR Art. 80 is a payment prohibition: persons trading in goods or providing services may not accept or make cash payments above EUR 10 000, with penalties for professional breaches. GwG Art. 8a is a due-diligence trigger: the cash payment above CHF 100 000 remains lawful, but it activates identification, beneficial-ownership and documentation duties on the dealer. Nothing in the Swiss texts reviewed caps the amount of cash a Swiss dealer may accept. The EUR 10 000 and CHF 100 000 figures are carried here in their own currencies; no conversion between them should be drawn from this note. AMLR Art. 80(4) additionally requires credit institutions and payment or e-money providers to report above-limit payments or deposits to the FIU; the GwG Art. 8a text carries no standing report-to-FIU duty at its threshold, though a suspicious case could separately trigger the general GwG reporting regime elsewhere in the Act. Since 1 October 2026 a lower CHF 15 000 trigger applies to precious-metal and precious-stone trading (GwG Art. 8a Abs. 2bis). ## Effective dates GwG Art. 8a's CHF 100 000 threshold applies; since 1 October 2026 a CHF 15 000 threshold applies to precious metals and stones (new GwG Art. 8a Abs. 2bis, inserted by the TJPG amending annex). AMLR Art. 80 applies from 10 July 2027. See [[Effective-dates timeline]]. ## Further connections *These links come from an article-by-article comparison of the primary texts. They add to the provisions listed at the top of this note and make no equivalence claim.* - [[GwG Art. 8a - Due diligence for dealers (cash|GwG Art. 8a]] — Both address cash payments to goods dealers, including linked or split tranches; AMLR caps the cash amount, GwG Abs. 1/3 only triggers CDD above the dealer threshold (CHF 100 000; CHF 15 000 for precious metals and stones). *(related)* ## Authoritative text > [!quote]- Regulation (EU) 2024/1624 (AMLR), Article 80 — English text (EUR-Lex, CELEX 32024R1624) > **Article 80** > *Limits to large cash payments in exchange for goods or services* > 1. Persons trading in goods or providing services may accept or make a payment in cash only up to an amount of EUR 10 000 or the equivalent in national or foreign currency, whether the transaction is carried out in a single operation or in several operations which appear to be linked. > 2. Member States may adopt lower limits following consultation of the European Central Bank in accordance with Article 2(1) of Council Decision 98/415/EC (47). Those lower limits shall be notified to the Commission within 3 months of the measure being introduced at national level. > 3. When limits already exist at national level which are below the limit set out in paragraph 1, they shall continue to apply. Member States shall notify those limits to the Commission by 10 October 2024. > 4. The limit referred to in paragraph 1 shall not apply to: > (a) payments between natural persons who are not acting in a professional capacity; > (b) payments or deposits made at the premises of credit institutions, electronic money issuers as defined in Article 2, point (3), of Directive 2009/110/EC and payment service providers as defined in Article 4, point (11), of Directive (EU) 2015/2366. > Payments or deposits referred to in the first subparagraph, point (b) above the limit shall be reported to the FIU within the deadlines imposed by the FIU. > 5. Member States shall ensure that appropriate measures, including the imposition of penalties, are taken against natural or legal persons acting in their professional capacity which are suspected of a breach of the limit set out in paragraph 1, or of a lower limit adopted by the Member States. > 6. The overall level of the penalties shall be calculated, in accordance with the relevant provisions of national law, in such way as to produce results proportionate to the seriousness of the infringement, thereby effectively discouraging further offences of the same kind. > 7. Where, by reason of force majeure, means of payment by funds as defined in Article 4, point (25), of Directive (EU) 2015/2366 other than banknotes and coins become unavailable at national level, Member States may temporarily suspend the application of paragraph 1 or, where applicable, of paragraph 2 of this Article and shall inform the Commission thereof without delay. Member States shall also inform the Commission of the expected duration of the unavailability of means of payment by funds as defined in Article 4, point (25), of Directive (EU) 2015/2366 other than banknotes and coins and of the measures taken by Member States to reinstate their availability. > Where, on the basis of the information communicated by the Member State, the Commission considers that the suspension of the application of paragraph 1 or, where applicable, of paragraph 2 is not justified by a case of force majeure, it shall adopt a decision addressed to that Member State requesting the immediate lifting of such suspension. ## Sources - AMLR Art. 80 — CELEX 32024R1624 - GwG SR 955.0, Art. 8a - GwG Art. 8a Abs. 2bis, 2ter — TJPG amending annex - EMKG SR 941.31, Art. 1 Abs. 1 (referenced, not independently verified in this pass)