MLR1PP7400 - Penalties Guidance: Parallel Regulations and breaches

These only apply to MSBs and HVDs.

Distinguishing between parallel breaches in both the 2003 and 2007 Regulations and breaches of specific new requirements within the 2007 Regulations is important when determining if a warning letter, penalty or criminal investigation is the most appropriate sanction.

• Warning letters are fully explained in MLR1PP6000 and Criminal Investigation in MLR1PP12150 
• The following are considered by us to be parallel breaches:
• Failing to keep customer records
• Failing to undertake identity checks up to the minimum customer due diligence standards in the 2007 Regulation
• Failing to appoint a Nominated Officer (where appropriate) and/or having internal reporting procedure for Suspicious Activity Reports (SARs) in place
• Failing to train staff in any of the above requirements
• Failing to tell us about registration details that have changed
• Failing to correctly register or re-register with us on time