Detailed guide: Money laundering supervision: who needs to register

Updated: This guidance has been updated to reflect legislation changes effective from 26 June 2017, including carrying out a business in the UK


Your business needs to be monitored by a supervisory authority if Money Laundering Regulations apply to your business type.

This guide will help you to decide if you need to register with HM Revenue and Customs (HMRC) under the regulations.

Businesses covered by the regulations

The regulations apply to a number of different business sectors, including accountants, financial service businesses, estate agents and solicitors.

Every business covered by the regulations must be monitored by a supervisory authority. Your business may already be supervised, for example, because you’re authorised by the Financial Conduct Authority (FCA) or belong to a professional body like the Law Society.

If not, and your business falls into one of 7 business sectors, you’ll need to register with HM Revenue and Customs(HMRC).

You can check if you need to register first.

Business types supervised by HMRC

HMRC is the supervisory authority for:

You need to register with HMRC if you carry out activities typically associated with these types of organisations by way of business and you aren’t already registered.

A business must not trade without registering with HMRC under the regulations. Trading while not registered is a criminal offence. It may result in a penalty or prosecution.

You may have to pay a penalty or face prosecution if you:

  • carry on your business without registering first
  • continue to carry on your business after you have deregistered or after HMRC has cancelled your registration

Businesses already supervised for money laundering purposes

You don’t need to register with HMRC if you’re already supervised by the FCA or are a member of a professional body, like the Association of Chartered Certified Accountants, that acts as a supervisory authority.

If you’re regulated by the FCA for another purpose, you should contact both them and HMRC to give the details.

Supervisory authorities

The supervisory authorities are:

  • HMRC
  • FCA
  • Gambling Commission

Some designated professional bodies also act as supervisory authorities, these are:

  • Association of Accounting Technicians
  • Association of Chartered Certified Accountants
  • Association of International Accountants
  • Association of Taxation Technicians
  • Chartered Institute of for Legal Executives
  • Chartered Institute of Management Accountants
  • Chartered Institute of Taxation
  • Council for Licensed Conveyors
  • Faculty of Advocates
  • Faculty Office of the Archbishop of Canterbury
  • General Council of the Bar
  • General Council of the Bar of Northern Ireland
  • Insolvency Practitioners Association
  • Institute of Certified Bookkeepers
  • Institute of Chartered Accountants in England and Wales
  • Institute of Chartered Accountants in Ireland
  • Institute of Chartered Accountants of Scotland
  • Institute of Financial Accountants
  • International Association of Bookkeepers
  • Law Society
  • Law Society of Scotland
  • Law Society of Northern Ireland

Businesses supervised by HMRC that also need to be registered or authorised with the FCA

Money service businesses that are required to register with HMRC and carry out money transmission will also need to be registered or authorised with the FCA under the Payment Services Regulations 2009.

The contractual agreements between businesses will affect what type of registration they’ll need from HMRC and the FCA respectively.

For instance, both branches and agents of a business must be listed as part of that business’s registration but only agents need to be registered with the FCA under the Payment Services Regulation.

Businesses that deal with each other whilst remaining independent of each other must register separately with both HMRC and the FCA.

How your business is registered is a matter for you but your registration with HMRC and the FCA must be consistent and appropriate. You may have agents, some of whom are registered with the FCA as your agents and others as Small Payment Institutions. You must register all such businesses as agents within your FCA registration and all the individual addresses must be listed on your HMRC registration.

You’re responsible for all the activities and anti-money laundering compliance of any premises or agents that are listed under your Money Laundering Regulations registration.

This includes, but is not limited to, the provision of training and the application of your businesses policies and procedures.

Some things to consider when deciding how you should register are:

  • who the customer enters into a contract with when transmitting money
  • if you have a written contract with another business to supply services on their behalf
  • who decides the charges and if appropriate any currency exchange rates
  • the responsibilities under the contract of both parties
  • if a computer system is used to maintain records, the business that supplies it and is responsible for its ongoing maintenance and development
  • the name that appears on documents such as order forms, receipts and contracts that are used and issued to customers
  • the payment service name that appears on the shop sign above the premises

It’s important to consider who the customer enters into a contract with. Although the agreement with your business partners may show that the customer has a contract with them, what matters is who is responsible to the customer if their money is lost.

Checking that your registrations are correct

HMRC checks for discrepancies between its register and the FCA register.

You should check your details with both HMRC and the FCA to make sure your registrations are correct. If there are any differences you should decide which registration is appropriate and change any registration details that are incorrect.

HMRC cannot tell you how you must register but it may challenge you if they believe your registration is incorrect.

If you have any questions about any of these matters please contact HMRC.

For FCA enquiries contact their Customer Contact Centre.

Carrying out an activity ‘by way of business’

In most cases you’ll know whether you’re carrying out an activity by way of business, but sometimes it may be difficult to know for sure. You can contact HMRC for further advice if you’re still unsure after you have read the guidance.

Charities and public sector bodies

Services that are provided by certain charities and public sector bodies aren’t covered by the regulations. This is because the services aren’t carried out by way of business.

The types of charity and public body that don’t have to register are:

  • UK registered charities that provide these services free or for a nominal charge
  • public authorities serving members of the public free of charge, or for a fee to cover the cost of providing the service only
  • public authorities that provide these services as part of their statutory duties and charge a fee
  • public authorities that are funded by the Exchequer or council tax payers, and not by the person who receives the service
  • public authorities or joint ventures (where 50% or more of the shares are owned by the public body) that provide services only to other public authorities
  • public authorities or joint ventures (where 50% or more of the shares are owned by the public body) that provide services to a firm authorised by a public body to act on their behalf – for example a housing association

Carrying out business in the UK

You’ll usually know if you’re carrying out activity in the UK, however, there are some circumstances where it may not be immediately obvious.

You’re carrying out business in the UK if:

  • your registered office, or head office if you don’t have a registered office, is in the UK
  • the day to day management of your business is by the registered or head office or another office in the UK

If you carry out business in the UK, you’ll need to register under the regulations in the UK. It doesn’t matter where your customers are located.

Source: HMRC

Detailed guide: Money laundering supervision: business inspections

Updated: This guidance has been updated to reflect legislation changes effective from 26 June 2017 clarifying the information the officer needs to see.


HM Revenue and Customs (HMRC) may check the compliance of your business using visits or office based compliance if it’s registered under the Money Laundering Regulations.

The purpose of a compliance check is to see that you’re complying with the regulations.

HMRC will look at how you operate your anti-money laundering policies and procedures and help you make sure you’ve put the right systems in place.

This guide explains what to expect if HMRC contacts you to arrange a check, so that you know:

  • who should be present
  • what the officer will focus on
  • which records they’ll want to see

Why HMRC visits businesses

HMRC makes sure that businesses registered with it are complying with the Money Laundering Regulations.

An officer may visit your business if information suggests there is a risk that your business may be exposed to money laundering. If HMRC does decide to visit your business this may not mean they think there’s something wrong.

When HMRC officers visit your business they’ll make sure you understand the regulations. It’s a good opportunity to ask about anything you’re unsure of.

They’ll look at your anti-money laundering risk assessment, policies, controls and procedures to check that you’re only doing what’s really necessary, and check you know about any simplified procedures you could take advantage of.

How HMRC will contact you to arrange a visit

If HMRC decides to visit your business they’ll generally contact you by phone to arrange a convenient time.

The officer will normally visit your main business premises so they can:

  • see how your anti-money laundering risk assessment, policies, controls and procedures work
  • have access to all the records and paperwork relating to your procedures
  • speak to the right people

You should let HMRC know if you want the visit to take place at a different business premises.

HMRC will write to you and confirm:

  • the date and time of the visit
  • who the officer will want to speak to
  • the information the officer will want you to give them
  • the records and documents the officer will want to see

HMRC will usually let you know in advance the names and contact numbers of the officer.

Exceptionally, HMRC may visit a business without making an appointment. If they do, the officer will:

  • identify themselves
  • give a reason for the unannounced visit

Who the officer will want to talk to during the visit

When the officer arrives at your business premises they’ll need to talk to the owner of the business.

After that, as the owner of the business you don’t need to be there so long as a responsible person is present who can:

  • answer the officer’s questions
  • give the officer any documents or information they need

Your manager (or the person in the business who’s responsible for complying with the regulations if that’s someone else) should always be there during the visit.

The officer will look at your risk assessment, policies, controls and procedures and test them to make sure they’re working properly.

They’ll need to speak to you as the business owner, your senior managers and sometimes other members of staff to make sure you all understand the policies and procedures and have applied them in your business.

Professional advisers

You can ask a professional adviser to be there during the visit but they can’t stand in for you. Only you can answer the officer’s questions about your business.

Your adviser may be able to explain things better or make things clearer, especially if they were involved with setting up your anti-money laundering policies and procedures or with staff training, but they may charge you for this.

What the officer will do during the visit

When the officer arrives at your premises they’ll identify themselves and show you their identity card.

They’ll focus on your anti-money laundering risk assessment, policies, controls and procedures to make sure these are working effectively to identify and reduce the money laundering risks your business might face.

The officer will always:

  • check that the information on the HMRC register is correct
  • check that the right people have taken the fit and proper test if your business is a money service business, a trust or a company service provider
  • check the right people have approval from HMRC if your business is an accountancy servicer provider, estate agency business or a high value dealer
  • look at the risk assessment of your customers, products and services
  • look at the policies, controls, procedures and training you’ve put in place to manage and reduce the risks you’ve identified
  • ask you to explain how your anti-money laundering risk assessment, policies, controls and procedures work

They’ll also answer any questions you might have about your legal responsibilities under anti-money laundering legislation.

The officer may also carry out some the following checks:

  • examine your records of transactions
  • check your customer due diligence procedures
  • see how effective your systems are for identifying and reporting suspicious activity to the National Crime Agency (NCA)
  • check that your staff know about anti-money laundering legislation and that they’re trained to recognise and deal with suspicious activity
  • make sure you’ve got the right systems in place

The officer may inspect any cash they find on your premises if you’re a high value dealer or a money service business.

They’ll check that your anti-money laundering risk assessment, policies, controls and procedures cover pawnbroking if you offer this as part of your money service business.

Records the officer will want to see

In addition to other checks, the visiting officer might ask to see:

  • internal audits of how you’ve complied with internal anti-money laundering procedures and controls
  • an external auditor’s report, if this covers your business’s compliance with the regulations
  • relevant bank statements
  • copies of and references to material proving a customer’s identity
  • training records
  • a job description of the senior manager in your business who is responsible for complying with anti-money laundering legislation
  • records of suspicious transactions and of the action you took
  • copies of any Suspicious Activity Reports you submitted to the NCA, and any correspondence from the NCA concerning consent to proceed

The officer will only look at Suspicious Activity Reports for anti-money laundering legislation purposes. They won’t look at them for tax purposes.

At the end of the visit

HMRC aims to carry out their visit as quickly as possible. Unless you’re a large or complex business it’ll usually take less than a day.

At the end of the visit the officer will:

  • review with you what they’ve done
  • explain any areas of concern
  • agree with you any action you need to take
  • answer any questions you have

After the visit

After the visit HMRC may send you notes of the meeting. This is an opportunity for you to make any amendments and send them back within the deadline.

The interval between visits

The length of time before HMRC visits your business again varies. It depends on:

  • the size of your business and how complex it is
  • what type of customers you have
  • your previous record of complying with the regulations

Office based compliance checks

HMRC may decide to conduct office based compliance checks such as a telephone or desk based check. If they decide to do this they’ll contact you by post or telephone to arrange a time and date. They will request the same information and records as when carrying out a visit.

The purpose of an office based check is the same as a visit and similar checks may be carried out.
Our officers will make sure they are speaking to a responsible individual within the business such as the business owner or senior manager.

In many cases an office based check will be enough to test the compliance of your business. However, HMRC may need to use other types of checks to follow up if your business is complex or there are concerns that need further investigation (for example, a telephone check to complete visit or a visit following a telephone check).

After a compliance check

HMRC will write to you to:

  • set out any action you need to take
  • warn you if you may be liable to pay a penalty or other sanction (although businesses that follow the HMRC guidance won’t be liable to a penalty and will have protection from prosecution)

They’ll give you a reasonable amount of time to let them have any information they need, and to put right any problems.

Source: HMRC

Detailed guide: Money laundering supervision: fees

Updated: You’re now able to pay your fees online when you register or renew for anti-money laundering supervision with HMRC.


You must pay HM Revenue and Customs (HMRC) fees when you register for anti-money laundering supervision.

These are:

  • an application submission fee
  • a registration fee for each premises
  • an annual renewal fee for each premises

If you’re a money service business or a trust or company service provider you’ll also pay responsible person fees.

Application submission fee

You must pay a non-refundable application charge of £100 when you first apply to register for anti-money laundering supervision.

Premises fee

When you register you must pay £115 for each of the premises you include in your application.

Annual renewal fee

Towards the end of your registration year HMRC will send you an email telling you to log in to your account to renew your registration and pay your renewal fee.

The renewal fee is £115 for each premises shown on the application at the time of renewal.

HMRC may cancel your registration if you don’t pay your annual renewal fee on time.

Fit and proper test fee

If your business is a money service business or a trust or company service provider a fit and proper test will be included in your application to register with HMRC.

There’s a £100 fee for each responsible person the test is applied to.

How to pay the fees

You’ll pay your fees online when you first apply to register and when you renew your registration online. When you input details of your business, the online service will calculate how much you owe and let you pay the total amount due for each type of fee.

If you’ve not yet registered online

If you’re not registered online and need to pay your renewal fees or a fee for an additional nominated person, there’s a variety of ways you can make your payment.

How HMRC use the fees you pay

HMRC use the fees to:

  • provide the advice and guidance you need to meet your Money Laundering Regulations responsibilities
  • carry out checks to make sure businesses are doing all they need to under the regulations
  • work with other organisations, for example assisting the National Crime Agency with prosecutions

Source: HMRC

Notice: VAT Notice 702: imports

Updated: The email address for National Duty Repayment Centre (NDRC) enquiries has been updated.

This Notice 702 (May 2017) cancels and replaces Notice 702 (December 2016). Details of any changes to the previous version can be found in paragraph 1.2 of this notice.

Source: HMRC

Guidance: Automatic Exchange of Information: registering and reporting guidance

Updated: The steps for creating an account to access the AEOI service have been updated.

Guidance on registering an account to access the AEIO online service and guidance for financial institutions to report information to HMRC.

You can check if there are any current problems with this service, or times it won’t be available. HM Revenue and Customs services may be slow during busy times.

Source: HMRC