HMRC Fit and Proper Test

Will poor credit history and a time to pay arrangement cause failure?

Didn't find your answer?

I have a few questions regarding HMRC's Fit and Proper test for Accounting Services & TCSP. Keen to get some insights. FYI I am a General Manager, but not performing the accounting/ TCSP function. I do however perform the KYC/AML function.

  • Do they do a credit check? And if so, will a poor credit rating / credit history / large amount of credit affect the test's outcome?
  • Do they care about qualifications? E.g. educational background not in accounting / limited experience in the sector. I do have an anti money laundering course certificate.
  • Will being on a Time To Pay (TTP) for personal income taxes affect my application?

Replies (5)

Comments for this post are now closed.

David Winch
By David Winch
28th Nov 2023 23:49

Short answer, No.
David

Thanks (2)
avatar
By Postingcomments
29th Nov 2023 11:05

Being on this site has opened my eyes to how many suspect people there are in this profession, if you can call it that.

Like a few months ago, when we had that flurry of people asking if they would be kicked out of the prof bodies after being convicted of this or that and wondering if they should keep it quiet.

Thanks (1)
Replying to CashFlowCaptain:
avatar
By Postingcomments
29th Nov 2023 11:37

In the context of working in accountancy/finance, yes.

If you have failed to exercise proper stewardship over your money, it is a bit rich to describe yourself as "fit and proper" to have a position of responsibility over any kind of financial affairs.

Thanks (1)
Replying to CashFlowCaptain:
avatar
By FactChecker
29th Nov 2023 12:09

You're drawing the wrong conclusion (in the context of your original posted topic).

These, and many other, factors do not inexorably lead to an absolute conclusion (such as trustworthy yes/no) ... but they are contributory input to any assessment of risk and, as such, will 'raise a flag' for consideration by humans.

So ... not an automatic bar, but nor entirely irrelevant.

Thanks (1)
Replying to FactChecker:
David Winch
By David Winch
29th Nov 2023 12:24

I read this query by the OP as referring to the Fit and Proper test in Reg 58 MLR 2017 and I am assuming that the OP classes himself as a "manager" in this context because he has a KYC/AML function. I assume however that he is not the MLRO.
The OP says he has an anti-money laundering course certificate and, for this purpose, knowledge of and understanding of MLR requirements is important (and accountancy knowledge is not). If he is a "manager" for MLR purposes (i.e. a BOOM) then getting a DBS basic check may be necessary (depending upon the stance taken by the firm's supervisory body).
So "No" was the short answer!
David
P.S. to get a DBS basic check in England & Wales use this link
https://www.gov.uk/request-copy-criminal-record

Thanks (1)