Which businesses are required to register with a supervisor for Anti-Money Laundering (AML) purposes? Who is your supervisor for (AML) purposes?
This is a freeview guide.
Many types of UK businesses and individuals must register with a supervisory authority in order to comply with the UK's Money Laundering (ML) regulations. They include:
- Financial and credit businesses.
- Barristers, lawyers and conveyancers.
- Accountants, tax advisers, auditors and insolvency practitioners.
- Trust and company service providers.
- Estate agency businesses.
- Letting agency businesses (rentals of €10,000 or more in a month)..
- Casinos.
- High-value dealers (handling cash payments of €10,000 or more in exchange for goods).
- Art market participants (buying, selling or storing art worth €10,000 or more).
If you run a business in one of these areas, you must register with your appropriate supervisor.
Who is your supervisor?
HMRC is a supervisor for the purposes of Money Laundering Regulations (MLRs).
Many professional services firms such as lawyers, accountants, tax advisers and bookkeepers are supervised by their own Professional Body Supervisor (PBS) for which they are members.
If you are not a member of a professional body that is a PBS, or you are a Trust and Company Service Provider (TCSP), running an Estate Agency Business (EAB) or Letting Agency Business (LAB), Money Service Business (MSB) or a high-value dealer and art dealer, then HMRC is your supervisory body and you must register directly with HMRC.
HMRC has the power to suspend as well as fine businesses and the law allows it to name firms in breach of the AML regulations.
HMRC's recent lists of fines reveal that many firms of Accountancy Service Providers, Estate Agency Businesses and Money Service Businesses, in particular, have all been falling short of their AML compliance obligations.
|
Sector |
Supervisor |
|
Legal sector |
PBSs (e.g. Law Societies in England, Scotland etc, Bar Association, conveyancers etc) |
|
Accountancy Service Providers (ASPs) |
PBSs (e.g. ACCA, ATT, AAT, CIOT, ICAEW, ICAEW) HMRC |
|
Trust and Company Service Providers (TCSPs) |
HMRC (where not supervised by a PBS, FCA or HMRC (as an ASP)) |
|
Estate Agency Businesses (EABs) |
HMRC |
|
Letting Agency Businesses (LABs) |
HMRC |
|
Money Service Businesses (MSBs) |
HMRC (where not supervised by FCA or GC) |
|
Art market participants (AMPs) |
HMRC |
|
High-Value Dealers (HVDs) |
HMRC |
|
Bill Payment Service Providers/Teleco communication, Digital and IT Payment Service Providers |
HMRC (where not supervised by FCA) |
Who are the PBSs?
The Professional Body Supervisors comprise:
Association of Accounting Technicians
Association of Chartered Certified Accountants
Association of International Accountants
Association of Taxation Technicians
Chartered Institute of Legal Executives/CILEx Regulation
Chartered Institute of Management Accountants
Chartered Institute of Taxation
Council for Licensed Conveyancers
Faculty of Advocates
Faculty Office of the Archbishop of Canterbury
General Council of the Bar/Bar Standards Board
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 Bookkeepers
Law Society/Solicitors Regulation Authority
Law Society of Northern Ireland
Law Society of Scotland
Useful guides on this topic
AML: Anti-Money Laundering glossary
Do you know your ASP from your EAB? Do you have a PBS or are you a BOOM? Anti-Money Laundering (AML) guidance loves an abbreviation. Here is a useful list.
AML Zone: Anti-Money Laundering tools for you
AML Zone contains checklists and practical guidance on the Anti-Money Laundering requirements that businesses need to follow.
You can also watch our Anti-Money Laundering Update and Compliance course on demand.
- Time for your firm-wide risk assessment? New to AML compliance? Need help working through your AML verification checks?
- Check out our Anti-Money Laundering Update and Compliance course.
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