I use a number of self-employed sub-contractors to prepare final accounts
One of my subbies has given me a copy of her HMRC Certificate of Registration for Money Laundering Regulation.
She tells me she has read of an accounting firm who have been fined for using an un-registered sub-contractor
Is it our responsibility to ensure that our subbies are registered?
Many thanks
Martin
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Sub-contractors
You may wish to be aware of this guidance from HMRC in relation to self-employed subcontract accountants (who may NOT be required to register with HMRC themselves in the circumstances described):
If all your customers are Accountancy Service Providers
If all your customers are Accountancy Service Providers who are supervised by HMRC or a professional body you don't need to register so long as you meet all of the following conditions:
you don't do business directly with the supervised Accountancy Service Providers' own customers you're included in the supervised Accountancy Service Providers' anti-money laundering controls and procedures, suspicious activity reporting, and training programmes you have a written contract with each of your customers confirming that every aspect of the relationship between you meets all anti-money laundering requirements
Does that help?
David