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Money Laundering Regulations – Who Needs To Register?

It’s not just accountancy firms and tax officials who have obligations in relation to money laundering. HMRC also expect many others to play a role too.

Your accountant is expected to be able to identify potential money laundering situations. We are also obligated to report suspicious activity to the relevant authorities. We are regularly reminded of this responsibility by our professional body. It’s all part of ensuring that businesses and organisations observe the highest standards and conduct their affairs under the proper legal framework.

What’s less well known is that a number of other businesses are also required to be registered with HM Revenue & Customs (HMRC) for the purposes of monitoring money laundering. These range from estate agents and car dealers through to jewellers and builders.

What is money laundering?

The UK Government describe money laundering as “exchanging money or assets that were obtained criminally for money or assets that are ‘clean’. Money laundering also includes money that’s used to fund terrorism”.

Registering with HMRC

The money laundering regulations apply to a number of different business sectors handling money. Some businesses covered by the regulations will be supervised by a supervisory authority or professional body. For example, the Law Society or the FCA.

If your business is not supervised and falls into one the following business sectors you will need to register with HMRC. HMRC will be your supervisory authority.

Money Service Businesses

This is where you act as a bureau de change, transmit money or cash cheques. If you’re not already supervised by the Financial Conduct Authority for the purposes of the Money Laundering Regulations, then you must register with HMRC.

High Value Dealers

You will be categorised as a High Value Dealer if you take a single cash payment of €10,000 or more. You will also be categorised as one if you take several cash payments adding up to this amount. Car and boat dealers, antique dealers and auctioneers may fall into this category. It may also include bathroom and kitchen suppliers and builders.

Trusts or Company Service Providers

This refers to companies and sole practitioners who form companies, provide registered office services and/or business addresses or act in a number of similar capacities.

Accountancy Service Providers

Here we are not just talking about auditors, accountants and tax advisors, but also external people (not employees) who provide professional bookkeeping services and help prepare accounts.

Estate Agency Businesses

Are you acting on the instructions of a customer who wants to buy or sell commercial or residential property? Or are you introducing to a customer someone who wishes to buy or sell property? If so, you will need to be registered.

In addition bill payment service providers and telecommunications, digital and IT payment service providers who are not supervised by the FCA are required to register with HMRC.

For more information on businesses that are required to register with HMRC click here.

Complying with the regulations

If your company is required to register with HMRC there is support on the website. This site details how to register and what actions you will be required to take under the money laundering regulations.

You can also contact us or your accountant for advice and support on implementing controls and ensuring you comply with the Money Laundering Regulations.

Andrew Picker



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