ECSH33015 | Working with advisors

Advisors play a vital role in helping our supervised population understand and meet their compliance obligations. An advisor might be an accountant, legal representative or external compliance specialist.

A business is not required to have an advisor but may choose to appoint one. However, you must remember the business is still responsible for its own compliance, and they should make sure their advisor has all the relevant facts about their business.

If the business wants their advisor to correspond directly with you throughout the intervention, ensure you have the correct protocols in place. You need the business’s consent; a 64-8 form Authorising an agent to deal with your tax affairs is only relevant to tax and separate written authority is needed to discuss anti-money laundering matters. You can find more information regarding how a business authorises a tax agent and the taxes they relate to in the Compliance Handbook.

If the business agrees to the use of email, the DSC1 or DSC2 must be sent directly to the business, not the advisor. For guidance on these documents, see ECSH111000 and ECSH32812. It is acceptable for an advisor to be present during the intervention but you should remember that they cannot answer for the business. See How HMRC checks on businesses registered for money laundering supervision . Be mindful that your role is not to up-skill the advisors or agents during the meeting.