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.


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