MLR1PP8200 - Penalties Guidance: The minimum starting penalty

The Regulations do not specify that there should be a minimum or maximum penalty but to make the transition from the 2003 Money Laundering Regulations and to make our penalty framework as simple as possible, the minimum starting point for the majority of penalties has been set at £5,000. This will also ensure that all our penalties which include a fine are dissuasive. The £5,000 minimum penalty will apply even if a business has made a loss.

The £5,000 minimum starting point however, does not apply to late registration breaches. Late registration breaches are based on a fixed penalty fee and any unpaid fees by the business. See MLR1PP8110


  • The level of the minimum penalty will be updated from time to time by our MLR Policy Team to ensure that the penalty framework continues to meets its stated objectives. Any changes will be published in advance on our website. See MLR1PP2110
  • The key points to remember are that:
  • The starting penalty for failure to notify penalties is £5,000 because there is no additional penalty. See MLR1PP8100 
  • The starting penalty for all other breaches with the exception of late registrationis the £5,000 minimum starting penalty plus an additional starting penalty. See MLR1PP8250 
  • When a business's gross profit is less than £50,000 the penalty cap means that there is no need to consider an additional starting penalty. See MLR1PP9150

(This text has been withheld because of exemptions in the Freedom of Information Act 2000)