Accountancy Service Providers and Money Laundering Regulations
Businesses that provide professional accountancy, tax or bookkeeping
services are known as 'Accountancy Service Providers'. The Money Laundering
Regulations require Accountancy Service Providers to register with HMRC
if they're not already supervised by a professional body.
This guide will help you decide if you need to register as an Accountancy
Service Provider and includes links to information on how to register.
On this page:
Accountancy Service Providers and the Money Laundering
The Money Laundering Regulations don't just apply to businesses that
criminals could use to launder money. They also apply to businesses
that could notice or suspect that their client's business is being used
for money laundering, or for any other criminal activity. Accountancy
Service Providers come into this category.
What is an Accountancy Service Provider?
For the purposes of the Money Laundering Regulations, HMRC uses the
term Accountancy Service Provider to describe:
- auditors who carry out statutory audit work
- accountants who are in business to provide accountancy services
- tax advisers who are in business to provide advice to clients about
their tax affairs
What are accountancy services?
Accountancy services cover recording, reviewing, analysing, calculating
and reporting on financial information for other people. They include:
- professional bookkeeping services
- accounts preparation and signing
- tax advice
What is tax advice?
Tax advice includes:
- helping with filling in and submitting tax returns or duty claims
- advising on whether something is liable to a tax or duty
- advising on the amount of tax or duty that is due
When you need to register as an Accountancy Service
Types of business that are typically covered by the Money Laundering
- tax advisers and tax consultants
- payroll agents if they provide accountancy services and/or tax
advice - for example, if they calculate the tax liability, earnings
or payments that are made to a business' employees or subcontractors
- Customs practitioners, freight forwarders and similar businesses
if they provide accountancy and/or tax services
- interim (or temporary) managers who carry out any of the activities
of the businesses listed above
Note that the regulations apply even to very small businesses, or where
a business only does one part of a transaction. So you'd still need
to register with HMRC if you were a bookkeeper with just one client,
for example, or if you only kept a client's business records from which
their accountant prepared the accounts.
Carrying out an activity 'by way of business'
In most cases you'll know whether you're carrying out a relevant activity
by way of business, but there may be some circumstances where you might
not be sure.
If you already know that you are in business you do not need to consider
this any further
If you are unsure, you will need to consider the following questions:
- Are you undertaking one of the activities listed above?
- Do you advertise or publicise your business activity, or receive
referrals from other businesses?
- Do you aim to make a profit when you carry out this activity?
- Do you carry out the activity with reasonable or recognisable continuity?
If you answer yes to all of these questions, you are carrying out
the activity by way of business. So your business activity needs to
be supervised under the Money Laundering Regulations and you'll need
to register with HM Revenue & Customs (HMRC).
If you answer 'No' to all of these questions, you aren't carrying out
the activity by way of business. So you don't need to register with
If you answer 'no' to some of these questions and you're still not
sure, you can contact HMRC for further guidance by email or, if you
prefer, you can write to them. Details are available in the section
below: 'If you're unsure whether you need to register with HMRC'
Remember to provide HMRC with your answers to all of the above questions
when you ask them for guidance.
When you don't need to register with HMRC as an Accountancy
You don't need to register with HMRC if any of the following apply:
- You're in business as an Insolvency Practitioner. You'll be supervised
by the Insolvency Service instead.
- You provide tax advice or accountancy services on a non-commercial
basis, for example within your own organisation rather than to a third
party. You're outside the scope of the regulations because you don't
provide these services as your business.
- You provide certain payroll services that don't include tax advice
or accountancy services.
Payroll businesses that are outside the scope of the regulations
If your business provides payroll services to a third party, you're
not an Accountancy Service Provider for the purposes of the Money Laundering
Regulations if you:
- provide software or hardware service support for payroll data processing,
as long as you don't analyse or prepare any financial information
- pay invoiced service fees to self-employed people, umbrella companies,
partnerships or other corporate service providers
- operate as a body like an umbrella company or a managed service
company and carry out payroll functions for employees who are working
on assignments for an end-user client
- provide recruitment or human resources management services and
carry out payroll functions as just a small part of your main business
activity - for example, you might be an employment business that supplies
or manages temporary or contract workers
Accountancy Service Providers already registered or supervised elsewhere
If you are an Accountancy Service Provider you must register with HMRC
- you're already supervised for Money Laundering Regulations purposes
by a professional body
- all your customers are themselves supervised by HMRC or a professional
The main supervisory bodies
For the purposes of the Money Laundering Regulations the main supervisory
bodies for accountants, bookkeepers, tax advisers and other financial
- Association of Accounting Technicians
- Association of Chartered Certified Accountants
- Association of International Accountants
- Association of Taxation Technicians
- Chartered Institute of Management Accountants
- Chartered Institute of Taxation
- Financial Conduct Authority
- Institute of Certified Bookkeepers
- Institute of Chartered Accountants in Ireland
- Institute of Chartered Accountants in Scotland
- Institute of Chartered Accountants of England and Wales
- Institute of Financial Accountants
- International Association of Book-keepers
- The Law Society
If you're supervised by one of the bodies above you don't need to register
If all your customers are Accountancy Service Providers
If all your customers are Accountancy Service Providers who are supervised
by HMRC or a professional body you don't need to register so long as
you meet all of the following conditions:
- you don't do business directly with the supervised Accountancy
Service Providers' own customers
- you're included in the supervised Accountancy Service Providers'
anti-money laundering controls and procedures, suspicious activity
reporting, and training programmes
- you have a written contract with each of your customers confirming
that every aspect of the relationship between you meets all anti-money
When businesses like customs practitioners don't have to register
If you're in business as a customs practitioner, a freight forwarder
or a similar occupation, you're not covered by the Money Laundering
Regulations if you only provide services like:
- helping your clients with classifying or valuing exports and imports
for customs purposes
- helping clients to comply with customs and other procedures, like
using simplified declaration procedures or facilities like warehousing
- helping clients with import or export licensing, and submitting
import and export declarations on their behalf
- paying duties, taxes and levies on behalf of importers
To be outside the scope of the regulations your services must only
cover the procedural aspects of these activities. You mustn't provide
any tax advice or accountancy services.
If you're unsure whether you need to register with
There is more detailed guidance to help you decide if you need to be
registered in the leaflet MLR9 Registration Notice. You can follow the
link below to download a guidance flowchart.
Download the tax adviser guidance
flowchart (PDF 24K)
If after reading this guidance you are still unsure or need advice
about whether you are carrying out relevant activities 'by way of business'
you can contact HMRC for further guidance.
Registering with HMRC as an Accountancy Service Provider
To register with HMRC you'll need to fill in a registration form and
provide all the information requested. You can find out more about how
to do this by following the link below.
How to register under Money Laundering Regulations