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AML Registration

Retrospective AML Registration

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Dear All,

I have held an AML registration with HMRC for a couple of years and I set up a company in 2019, but started actively trading in February 2020 offering my accountancy services. I am not a member of a professional body. 

I have reguarly updated my AML to reflect changes in staffing, turnover etc. and I have also been trying to change my status/name to a company but was unable to and also unable to get through to anyone during lockdown. 

I have finally got through to someone, and they have explained that I need to make a new registration as it is a seperate legal entity, which I have now done and I backdated it to the point at which I offered my services to clients. 

My questions are: 

Will this be rejected

Will I receive a fine? 

I am registered already as a tax agent ( I have already changed the name of this account to my company name) but will I need to apply for another tax agent account which is linked to my new AML registration or wont this matter?

I have emailed the AML team to explain what has happened as I was unaware a seperate application was required, and that I have been trying to contact them for months, and I have been advised that I will have to wait for at least 25 working days for a reply. 

Any opinions or advice would be most appreciated!


Replies (3)

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panda ketteringUK
By ketteringUK
31st Jul 2020 23:59

Most likely you will need to apply for new agent codes as these are no longer transferable. You really need to constantly email Bristol and Edinburgh units as things are slow at their end.
Also nowadays you will need full fit and proper test as part of the application.

I changed last year st to ltd and had many issues, some still ongoing. Luckily i found a very helpful contact at mlr dept which unblocked my agent codes whilst waiting for the new approval.

Thanks (1)
Replying to ketteringUK:
By legerman
01st Aug 2020 10:46


Also nowadays you will need full fit and proper test as part of the application.

Only if you're providing Ltd Co formation or registered/business address facilities, otherwise its an approval test (no unspent convictions for dishonesty/theft/fraud etc)

Thanks (1)
By jame2020
01st Aug 2020 12:07

In some cases yes I set up companies and use my office as a registered address

When I completed the application, I indicated all my services but I don’t think I seen that as an option to indicate?

Am I right in assuming the fit and proper persons test would be carried out as part of my application automatically or do I need to do this separately?

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