Do you need to register with HMRC for Money Laundering Regulations?

Money Laundering Regulations apply to a number of different business types. If the regulations apply to you, your business needs to be monitored by a supervisory authority.

It's possible that your business is already monitored, for example because you belong to a designated professional body or because your business is registered with an authority like the Financial Services Authority.

But if your business isn't already monitored, and it falls into one of four designated business sectors, you'll probably need to register with HM Revenue & Customs (HMRC), although there are a few exceptions.

This guide will help you to decide if you need to be registered with HMRC under Money Laundering Regulations.

On this page:

Which businesses are covered by Money Laundering Regulations?

The regulations apply to a number of different businesses, including:

  • most UK financial and credit businesses such as currency exchange office, cheque cashers or money transmitters
  • independent legal professionals
  • accountants, tax advisers, auditors and insolvency practitioners
  • estate agents
  • casinos
  • 'High Value Dealers' - businesses that accept cash payments for goods worth 15,000 euros or more either in a single transaction or in installments
  • Trust or Company Service Providers

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Are you already supervised for money laundering purposes?

Some businesses covered by the Money Laundering Regulations are already supervised by a designated supervisory authority like the Financial Services Authority (FSA), or by a professional body like the Law Society that acts as a supervisory authority. So they don't need to register with HMRC.

Supervisory authorities

The supervisory authorities are:

  • HMRC
  • FSA
  • Office of Fair Trading
  • Gambling Commission
  • Department for Business Innovation & Skills
  • Department of Enterprise, Trade and Investment in Northern Ireland

There are also designated professional bodies that 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 Management Accountants
  • Chartered Institute of Public Finance and Accountancy
  • 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 Book-keepers
  • Law Society
  • Law Society of Scotland
  • Law Society of Northern Ireland

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Business types supervised by HMRC

HMRC is the supervisory authority for the following four business types:

  • Money Service Businesses not supervised by the Financial Services Authority (FSA)
  • High Value Dealers
  • Trust or Company Service Providers not supervised by the FSA or a professional body
  • Accountancy Service Providers not supervised by a professional body

If you carry out activities typically associated with the above by way of business and you aren't already registered, you'll need to register with HMRC.

If you're not sure if your business falls within one of these four sectors you can find out more about the activities typically carried out by these businesses (including any exemptions) by following the links below.

Money Service Businesses and Money Laundering Regulations

High Value Dealers and Money Laundering Regulations

Accountancy Service Providers and Money Laundering Regulations

Trust or Company Service Providers and Money Laundering Regulations

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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. If, having read the guidance you are still unsure, it's a good idea to contact HMRC for further advice.

Contacting HMRC for guidance

If you need to contact HMRC for guidance on whether you have to register, you can email the Money Laundering Regulation Central Intervention Team.

Or if you prefer you can write to them at:

MLR Central Intervention Team
HM Revenue & Customs
7th Floor N/W
Alexander House
21 Victoria Avenue
Southend-on-Sea
SS99 1AG

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Do charities and public sector bodies have to register?

Money services, accountancy services and trust or company services that are provided by certain charities and public sector bodies aren't covered by the Money Laundering Regulations. This is because the services aren't carried out by way of business. So the organisations that provide them don't need to register with HMRC.

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 that provide these services for members of the public free of charge, or for a fee to cover only the cost of providing the service
  • 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 per cent 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 per cent 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

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Registering with HMRC and what happens if you don't

If you decide that you need to register with HMRC, you can find out what to do by following the link below.

How to register for Money Laundering Regulations

If you don't register when you should

You're committing an offence if you carry on a business activity that's covered by the Money Laundering Regulations and you're not registered with HMRC when you should be.

You may have to pay a penalty if you:

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

To find out more about penalties, follow the link below.

Appeals and penalties under Money Laundering Regulations

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