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Money laundering reporting requirement?

Hello

A training services provider has sent me a "VAT receipt" with VAT added to the training cost but no VAT number.

He has also done this to other people on the same course.

Despite numerous requests he has not provided a proper VAT invoice or receipt and so I have no evidence whether he is VAT registered or not.

Do I have to report this?

Replies

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25th Feb 2012 11:38

The question is . . .

Do you suspect VAT fraud?

Could it be that this business has only recently registered for VAT and does not yet have a number?  Could it be that the business issuing the 'VAT receipts' is just so clueless that they haven't realised that they should not charge VAT if they are not registered?

Your obligation to report to your MLRO / SOCA only arises under s330 PoCA 2002 / MLR 2007 if you know or suspect, or have reasonable grounds to suspect, money laundering.  There will be money laundering if a crime has been committed from which a benefit has been derived and someone knows or suspects it to be a benefit from crime.

If you do indeed suspect this to be the case then you are obliged to report it.  (It is irrelevant whether the person you suspect is, or has ever been, a client of yours.)

David

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