HMRC have opened a new consultation “Discussion Document on HMRC’s anti-money laundering supervision fees".

The Money Laundering Regulations apply to many business types.  

  • HMRC is the supervisory authority for several of these including Accountancy Service Providers not supervised by a professional body.
  • You need to register with HMRC before you commence trading or otherwise face penalties.  
  • The fee is currently £130 per premises and was increased from £115 in December 2017 with additional charges for other services such as fit and proper person tests.

HMRC is consulting on proposals to change the fees it charges and have identified three fee model options:

Option 1: Retain the current fees structure, but increase the level of fees significantly.

Question 1. Do you think the current fees model is a reasonable way of charging businesses to cover our costs?

Option 2: Alter the fee structure to:

  • No longer use the number of premises.
  • Charge a two part fee; a flat fee of £100 per business plus a low turnover based fee, e.g. 0.03%.

Question 2. Do you think this method of calculating fees is a reasonable way of charging businesses to cover our costs?

Question 3. Are you content with the method of calculating turnover above or can you suggest any better methods?

Question 4. Would you be willing and able to provide details of your businesses turnover using the above definitions to allow HMRC to calculate your fee?

Option 3: Retain the current approach:

  • With a scaled fee for each premise the business operates from.
  • The premises fee then increases with the number of premises a business registers with HMRC.
    • The business pays a different rate for each charging tier or
    • Moving up to the next tier means the business pays the highest rate for all of its premises.

Question 5. Do you think a scaling premises fee is a reasonable way of charging businesses for supervision?

Question 6. If you have a large number of premises, are you concerned this approach would be too complex if there is a different fee for premises in each tier?

HMRC is also proposing new administration charges:

Late renewal administration charge:

  • a flat fee of £100
  • a fee of 5 per cent of the registration fee, subject to a minimum of £50
  • an escalating fee based on the lateness of the payment.

Question 7. Do you agree that an administration fee for late payment should be introduced?

Question 8. Which method of charging for this late administration fee do you think HMRC should introduce and what level do you think would be appropriate?

Fit and proper top up fee for the re-testing work HMRC does on fit and proper persons:

  • New scheme where everyone who has fit and proper status is re-tested on a risk sensitive basis and at least every five years.
  • An annual charge at one fifth of the fit and proper test fee, per fit and proper person in the business, which would currently be £20.

Q9. Do you think it is right to charge the fee for this work only to those who have fit and proper persons instead of accounting for it through the normal registration fees?

Q10. Do you think this is the best way to charge this fee? If not, please tell us what you think would be better.

Other questions:

Q11. Are you planning any changes in your business model for the future that you think HMRC should be aware of when planning our future fees structure?

Q12. Which is your preferred option for charging for supervision or would you prefer to continue with the current method but with an increased fee?

Q13. Do you have any other comments that you think we should know about when considering the fees structure?

The consultation closes on 28 September 2018. Responses should be sent to This email address is being protected from spambots. You need JavaScript enabled to view it..

Our guides:

Money laundering checks: Know your client

Money laundering Regulations: Accountants registration

External links:

Discussion Document on HMRC’s anti-money laundering supervision fees

HMRC's Money Laundering registration guides

 

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