Michelle Russell, director of investigations, monitoring and enforcement at the Charity Commission, said: ‘The Commission has seen an increase in the number of charities having cash seized from their fundraisers, agents and representatives at the UK border. The Commission’s advice is simple: don’t use cash couriers unless there is no other possible means of moving money.’

The Commission says cash couriering is known to be used by terrorist and criminal organisations to move money. If the police or ports officers are not satisfied that the source or end use of the cash being couriered can be accounted for it is likely to be seized under the Proceeds of Crime Act 2002 (POCA) or the Terrorism Act 2000 (TACT). This risks money being forfeited by the courts or taking a significant amount of time, inconvenience and cost to restore to the charity.

In addition the Commission says cash couriering is difficult to audit and to have adequate records and evidence of expenditure. There is no requirement for cash couriers to be registered as a money service business with HMRC so there is less assurance about their quality and reliability.

The Commission’s position is that formal banking systems should always be used where they exist as they provide the safest and most auditable means of transferring charitable funds.

It accepts that in exceptional circumstances, where other means of transferring funds are not available, that cash couriering may be the only option available, particularly where charities are operating in challenging environments overseas.

In such circumstances, the Commission expects as a minimum that the trustees will obtain insurance in the event of loss of the cash being couriered, and require the cash courier carries documents evidencing the source and destination of the funds and their association with the charity.

Charity records such as trustee meeting minutes should record the trustees’ decision to use a cash courier and a detailed risk assessment including the use of a cash courier, the particular context such as the country the cash will be transferred to, and the value of cash to be transferred in relation to the size of the charity’s total income should be maintained.

The Commission also says trustees should ensure that cash being transferred with a value of €10,000 or above is declared to the authorities.

Trustees should also carry out appropriate due diligence when using an agent or partner. The Commission says trustees should agree in writing what is expected from the agent, how much money is being carried and in what currency, when it is to arrive by, and who it is to be paid to and how at the end destination. This should be in place and agreed before the money is handed over.

The Charity Commission’s detailed warning on the use of cash couriers is here.