Client has upcoming MLR visit. Anybody had any dealings with these. Any info or heads up other than whats on HMRC MLR site re visits welcome.
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As a High Value Dealer your client is within the 'regulated sector' and subject to MLR 2007 compliance when - and ONLY when - he accepts a High Value Payment.
A High Value Payment is a payment for goods in which the amount is at least 15,000 euro (or equivalent) and which is paid in cash (i.e. notes and / or coins) or travellers cheques (so NOT ordinary bank cheques, credit or debit cards or bank transfers).
So he should have obtained (& retained copies of) ID documents for those persons who made HVPs to him.
He should also have considered money laundering risk in relation to those persons (& tailored his customer due diligence accordingly) & reported to his MLRO / the NCA where he has suspicions of money laundering (or terrorist property offences).
He needs himself & his staff to have undertaken appropriate training & to have appointed an MLRO & have appropriate staff procedures (e.g. for reporting to the MLRO) - unless he is a one-man-band.
If he can satisfy HMRC that he has all this covered he should be fine.
David
Is ML advice a service you offer your clients? Have you issued an engagement letter for it?
(From my limited experience) they will want to satisfy themselves that good customer due dilligence is being upheld and is robust. I don't know whether classic cars have benificial owners (as with yachts) or whether collectors use offshore accounts to trade but these clients would be of particular interest. I would be interested to hear of your / your clients experience after inspection.
Refer to Arthur Daley Autos t/a Little Earner Enterprises
Chiswick Flyover Sidings
Address for Service : Rockingham Club , Soho W1
We received a HMRC MLR visit about 1 year ago since we are an ASP who specialise in tax disputes. We have attended meetings with clients who are alcohol traders and have accepted large amounts of cash and are High value Dealers. It is important to have a MLR Policy & Procedures and a Risk Assessment in place together with ID documents.