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AML regulations for membership organisations

Do membership organisations have to comply with the MLR?

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And if so, who do they have to carry out AML checks on? Surely it cannot be on all members? What would they include in their policy statement?

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David Winch
By David Winch
28th Feb 2021 15:51

To make it simpler to understand, let's assume the membership organisation is an unincorporated golf club.
The club does not offer accountancy services, nor does it fall within any of the other types of business which are within the 'regulated sector' defined in MLR 2017 or Sch 9 Proceeds of Crime Act 2002. So the short answer to your question is, "No".
But have I misunderstood your question?

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Replying to davidwinch:
By Guilford Accounting
28th Feb 2021 15:53

No that is very helpful. The organisation I have in mind is a not for profit, limited by guarantee association providing membership services and training (not regulation) to its professional members. I have carried out AML checks on the directors (all volunteers) but was wondering about whether they should have a policy statement. I presume not?

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Replying to Guilford Accounting:
David Winch
By David Winch
28th Feb 2021 15:55

I cannot see any need for one.

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