ECSH82525 | Sanctions for non-compliance: financial penalties: introduction

Introduction

Regulation 76(2)(a) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) permits HMRC to impose a financial penalty of ‘such an amount as it considers appropriate’ on any person (P).

Regulation 76(3) MLR 2017 permits HMRC to impose a financial penalty on another person who was at the material time an officer of P if that person was knowingly concerned in a contravention of a relevant requirement.

Regulation 76(4) MLR 2017 does not permit us to impose a financial penalty on P for a contravention of a relevant requirement if the decision maker is satisfied that P took all reasonable steps and exercised all due diligence to ensure that the requirement would be complied with.