MLR1PP5060 - Penalties Guidance: Identifying registration breaches: Continued
- Breaches of Regulations 26 and 33, carrying out regulated activity as a MSB, HVD, TCSP, or ASP without being registered with us (when HMRC is the appropriate MLR supervisor). This means trading unsupervised.
Trading unsupervised can be a very serious breach because it is often indicative of involvement in money laundering or an attempt to hide from regulation to avoid implementing anti-money laundering controls. This in turn may indicate that a business is being used as a vehicle for money laundering, with or without collusion. A breach of this Regulation will normally be identified by either disclosure, or will be discovered during an Intervention or Compliance Visit. This may have been initiated as a direct result of third party information we have received. Both of these circumstances are to be treated differently.
