ECSH40531 | Businesses who can be solely supervised by another supervisory body: Accountancy Service Providers (ASPs)

ASPs can be supervised solely by HMRC, the Financial Conduct Authority (FCA), or one of the professional bodies listed in Schedule 1 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).

ASPs must register with HMRC unless:

• They are already supervised for money laundering regulations purposes by a supervisory body.

• All the business’ customers are themselves supervised by HMRC or another supervisory body.

Evidence to confirm that a business is supervised by a professional body

If in the course of processing an application for registration you discover that the business is currently supervised by one of the bodies listed in Schedule 1 of MLR 2017, the business does not need to register for supervision with HMRC.

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

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

Membership vs supervision

A professional body may have different membership packages which means that being a member of a professional body does not always include supervision under MLR 2017. You must ensure that the evidence provided specifically states that business is supervised under MLR 2017 by the professional body.

Trading whilst unregistered

If you find in the course of carrying out the relevant checks, that the business has been undertaking relevant activity without being registered for anti-money laundering supervision, then the business would be in breach of MLR2017 and a penalty for trading whilst unregistered should be considered.