What recession | AccountingWEB

What recession

Does HMRC know there's a recession and inflation is minimal?
The MLR registration fee has just increased by 26% to £120. We knew it was just another tax all along!

davidwinch's picture

Membership of a supervisory body

davidwinch | | Permalink

I know that some accountants / bookkeepers are giving careful consideration to joining one of the supervisory bodies recognised under the Money Laundering Regulations 2007 in consequence of the price hike. Their thinking is that the membership costs little more than the £120 charged by HMRC and they get various benefits thrown in.

David Winch


Yonder Dave | | Permalink

David. Which supervisory body charges membership of about £120 including MLR supervision?

Most professional bodies charge several hundred pounds a year membership and licencing fees and MLR supervision extra. I know a couple who charged £80 extra for MLR supervision last year and no doubt this extra charge will go up in time.

Yonder Dave

davidwinch's picture

Membership costs

davidwinch | | Permalink

I am not an expert on membership fees of the various bodies, and I certainly would not wish to be seen as recommending membership of any particular body (I have no views on their comparative merits) however I understand that membership of the Institute of Certified Bookkeepers, including practising certificate fee, runs out at about £132 per annum. There may be others at similar costs.

David Winch

ShirleyM's picture


ShirleyM | | Permalink

The FTA now offer MLR supervision and membership fees are very reasonable, and loads of other benefits too. (I am a member, but not an official, so this is a possible solution, not an advert)

davidwinch's picture

Can you clarify that, please?

davidwinch | | Permalink

I would be grateful if you could clarify what the FTA (Federation of Tax Advisers) offers as I was not aware that it was recognised as a supervisory body under the Money Laundering Regulations 2007.

The FTA website says that it offers a "complete anti-Money Laundering package" but it does not say that it acts as a supervisory body.

David Winch

Always a way round the rules

Anonymous | | Permalink

It seems to me that there is always a way round the rules, if one looks hard enough.
I suspect HMRC are unlikely to notice or even bother if you have not registered.

Jon Stow's picture


Jon Stow | | Permalink

It is my understanding that the FTA (Federation of Tax Advisers) is being merged into the Institute of Financial Accountants at the end of this month. The IFA is a recognised supervisory body re the MLR and I assume this is what the previous poster means by his / her comment.

ShirleyM's picture


ShirleyM | | Permalink

Your comment is correct. MLR supervision through FTA is because of the IFA merger. The FTA also put out regular newsletters on new tax legislation and reminders re existing legislation. The FTA also offer monthly online CPD training via BPP, which is extra to the subscription. Worth having a look at, whether you need MLR supervision, or not.

Sara R's picture


Sara R | | Permalink

I was under the impression as long as you check the individuals identity (e.g name, address, passport, d.o.b, driving licence) and run a sanction check this was aml compliant. Is this right?

davidwinch's picture

It's a good start!

davidwinch | | Permalink

Yes, initial confirmation of the ID in the way you outline is an important part of compliance with the Money Laundering Regulations 2007.

If you offer accountancy / tax / bookkeeping or payroll processing services as a business then you are an "external accountant" for MLR purposes and you need to have your compliance with the MLR supervised by a recognised supervisory body. If you are, for example, a practising member of ICAEW then they will also be your supervisory body for MLR. If you are not already registered with a supervisory body (there are 22 such bodies recognised for MLR) then you have to register with HMRC for supervision by them. The annual fee for this registration is being increased from £95 per office per year to £120 - hence the posting at the start of this thread.

If you are not too familiar with this stuff a good place to get information (for free) is the HMRC website. Search for "MLR8" which is a general guidance booklet outlining the principal areas you need to address.

Note however that as an "external accountant" you are required to follow the CCAB anti-money laundering guidance, not the HMRC guidance (although the two have much in common). You can get to the CCAB Guidance via

I hope that helps.

David Winch

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