Anti Money Laundering Registration

Anti Money Laundering (AML) RegistrationBusinesses with obligations under the Money Laundering Regulations (MLR) must be monitored by an approved supervisory authority. Some firms in the sectors requiring oversight will already be authorised by a regulator (i.e. the FCA), or supervised by a professional body (i.e. the Law Society). There are a number of sectors to whom the regulations apply, including: –

  • Financial & Credit Businesses
  • Independent Legal Professionals
  • Accountants
  • Tax Advisers
  • Auditors & Insolvency Practitioners
  • Estate Agents
  • Casinos

See the full list at

HMRC Supervision

Where a business carries on a business activity that is covered by the Money Laundering Regulations, it is a legal requirement to register with the supervisor who regulates that industry sector.

The Government advise on their website that “trading while not registered is a criminal offence [and] may result in a penalty or prosecution.”

Where a business falls into one of the 7 business sectors on the right and are not already supervised, they must register with HMRC who will monitor their compliance with the MLR.

More information on registering with the hmrc for aml supervision...
  • Estate Agency Businesses
  • High Value Dealers
  • Art Market Participants
  • Letting Agency Businesses
  • Money Service Businesses (where not already supervised by the Financial Conduct Authority (FCA))
  • Bill Payment Service Providers (where not already supervised by the FCA)
  • Telecommunications, Digital & IT Payment Service Providers (where not already supervised by the FCA)
  • Trust or Company Service Providers (where not already supervised by the FCA or an approved professional body)
  • Accountancy Service Providers (where not already supervised by a professional body)

Supervisory Authorities

  • HMRC
  • Financial Conduct Authority (FCA)
  • Gambling Commission

Fit and Proper Test for AML Supervision

Those supervised by HMRC are required to pass a fit and proper test to ensure that any responsible person meets the requirements of the Money Laundering Regulations. This test involves a series of checks conducted by HMRC and forms part of the registration process for those in the money services and trust and company service providers sectors.

  • The fit and proper test applies to: –
  • The person applying to register the business
  • The person running the business (on their own or in partnership)
  • Officers of the business (including any director and company secretary)
  • Senior managers (where directly engaged in providing the regulated activity)
  • The nominated officer
  • Benefiial owners of the business
  • Any person who is in effect directing the business
  • Agents of money service businesses and their beneficial owners, officers and senior managers

Professional Bodies Who Can Act as Supervisory Authorities

  • Association of Accounting Technicians
  • Association of Chartered Certified Accountants
  • Association of International Accountants
  • Association of Taxation Technicians
  • Chartered Institute of for Legal Executives
  • Chartered Institute of Management Accountants
  • Chartered Institute of Taxation
  • Council for Licensed Conveyors
  • Faculty of Advocates
  • Faculty Office of the Archbishop of Canterbury
  • General Council of the Bar
  • 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
  • Law Society of Scotland
  • Law Society of Northern Ireland

Anti Money Laundering Policy Template

If you have obligations under the Money Laundering Regulations and don’t want to develop your policies and procedures from scratch, our AML templates are already used by thousands of businesses. Professional, high quality and fully customisable; why reinvent the wheel when you can purchase AML, due diligence and risk management templates from Know Your Compliance Limited.