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KYC at car dealerships at a glance

Three rules cover 90% of day-to-day cases: cash (€10,000), splitting and business customers (UBOs). The quick check below immediately shows what to do for the deal. Find details and examples in the KYC article.

Rule 1

Cash of €10,000 or more: complete KYC before handover.

Rule 2

Splitting or installments: the total amount counts.

Rule 3

Business or authorization: verify representation and the UBO.

Note: General information only, not legal or tax advice for an individual case.

Quick check

Select a situation to show the relevant tasks and rules automatically. With no selection, all rules are displayed.

Result

Rules shown: 5

What to do

  • Select the situation above. Without a selection, all rules are shown.

Note: Suspicion does not depend on the amount. Escalate unusual circumstances internally and document them.

Rules for everyday sales

A concise overview. For background and examples, read the KYC article.

More details

Cash of €10,000 or more

Requirement

Cash accepted or paid out totaling at least €10,000, including installments.

What to do

  • Complete identification using an ID document and create a deal record before signing or handover.
  • Document the cash amount, date and responsible person.
  • For a business, also verify its register details, representation and ultimate beneficial owner (UBO).

Common mistake

Mistake: waiting to identify the party until the “final installment” arrives. KYC must begin earlier.

Splitting and partial payments

Requirement

Multiple cash payments, multiple payers or transactions close in time with a recognizable connection.

What to do

  • Treat them as linked transactions: the total amount counts.
  • Start KYC immediately, including with the first installment if the total cash payment is apparent.
  • Briefly document the connection in the record and why the amounts were added together.

Common mistake

Mistake: treating “2 × €9,000” as two separate transactions.

Business customer or authorized representative

Requirement

The buyer or seller is a business, or a third party acts or pays on behalf of a contracting party.

What to do

  • Verify the business using register data and check representation, such as managing director, commercial power of attorney or authorization.
  • Always identify the person appearing separately using an ID document.
  • Determine and document the ultimate beneficial owner (UBO).

Common mistake

Mistake: knowing only the managing director without checking the UBO or authority to represent.

Red flags and suspicion

Requirement

Unusual circumstances, regardless of the amount or payment method.

What to do

  • Escalate internally to a defined contact and document the decision.
  • Record the facts: indicator, explanation, decision and outcome.
  • Do not tell the customer about an internal review; avoid tipping off.

Common mistake

Mistake: recording only a “strange feeling” without evidence, or communicating the internal review to the customer.

Storage and deletion

Requirement

KYC records are not the same as invoices or tax documents.

What to do

  • Manage KYC records separately from tax documents under the separation principle.
  • Set a dedicated deletion date for KYC records, typically five years.
  • Invoices and contracts remain subject to tax-law retention periods, which are typically longer.

Common mistake

Mistake: storing everything in one folder without a deletion policy, creating a compliance risk.

Further resources

Once your KYC process is in place, documentation and archiving are the next typical audit priorities. These are the key resources.

Questions about KYC at car dealerships

When must a car dealership perform KYC?

When it accepts or pays out cash totaling at least €10,000, including economically linked partial payments.

Find more details in the KYC article .

What is splitting or smurfing in vehicle retail?

It is the division of one economically connected payment into several cash amounts. If a connection is recognizable, the total amount is decisive.

Find more details in the KYC article .

What additional checks are required for business customers?

Verify register details, authority to represent the business and the ultimate beneficial owner (UBO). Always identify the person appearing separately.

Find more details in the KYC article .

Where can I find details, examples and background information?

The detailed KYC article covers thresholds, splitting cases, UBO logic, goAML, retention and deletion.

Find more details in the KYC article .