Anti money laundering update
HMRC is reminding businesses that external consultants cannot act as the nominated officer for a third-party business – especially those that are registered with HMRC under the (Anti) Money Laundering Regulations.
This reminder follows a recent Financial Services Authority (FSA) investigation which found that a number of directors had been relying too heavily on external consultants for advice on how to run their businesses. This investigation resulted in three directors being banned from acting as senior managers for failing to meet their supervisory standards.
HMRC take the same view as the FSA in relation to businesses subject to the money laundering regulations. HMRC has no objection to businesses obtaining advice from external consultants but stress that the responsibility for complying with the regulations must remain with the business.
HMRC is responsible for supervising the following four business types if the business is not otherwise registered with an approved supervisory body:
- Money Service Businesses (MSBs)
- High Value Dealers (HVDs)
- Trust or Company Service Providers (TCSPs)
- Accountancy Service Providers (ASPs)