MLROs - client's registered office at yours?

A heads up for MLROs if your AML supervisor is HMRC

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I was helping a firm yesterday with their Anti Money Laundering compliance. It transpired that their AML supervisor was HMRC and that some of their limited company clients used the firm's address as their registered office address.  Nothing wrong with that (although I know some firms prefer not to do it).

The problem was that the firm was registered with HMRC as an Accountancy Service Provider but not also as a Trust or Company Service Provider.

This means that they are at risk of penalties because in these circumstances HMRC require the firm to register as both an ASP and a TCSP - and pay an additional fee and fill in extra forms.

So just a heads up - if this applies to your firm get it sorted before HMRC find it!

David

Replies (11)

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paddle steamer
By DJKL
12th Oct 2023 12:11

Excellent post, thanks.

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By Paul Morton
12th Oct 2023 12:23

I thought the supervision fee was an annual amount for the registered premises and would encompass both ASP & TCSP? I will need to review!

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By SJRUK
12th Oct 2023 12:25

Thanks for the heads up - I had better check what ours cover.

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By GHarr497688
12th Oct 2023 13:18

What a farce . I no longer offer TCSP services however as I was unable to change my registration because HMRC failed to process the renewal ( and still haven't done so ) I was told off at a AML visit for not removing that part of the registration. I emailed the team at HMRC on the advise of the visiting officer and now after four months and despite being promised a reply nothing has come through. HMRC have reprimanded me for failing to do something their systems won't allow and then when you inform them they ignore you. Any everyone is saying why are HMRC in such a mess. Thank goodness I am retiring on 31st December 2023.

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Replying to GHarr497688:
paddle steamer
By DJKL
12th Oct 2023 14:36

Congratulations and enjoy. my wife is doing similar at end of November and is now busy plotting her retirement, I am continuing another couple of years.

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Replying to DJKL:
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By Postingcomments
13th Oct 2023 15:47

She is planning on travelling the world with GHarr.

Announcement to be made after Christmas, so as not to spoil the festivities!

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By Cylhia66
13th Oct 2023 07:11

Thanks David. I just updated my details and in case others are concerned about this there was no extra fee to pay.

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By lordofsums
13th Oct 2023 16:47

I know this has been a requirement for some accounting bodies as AML providers for a few years now

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Replying to lordofsums:
David Winch
By David Winch
14th Oct 2023 14:43

The different supervisory bodies deal with this (and other things!) differently. HMRC certainly expect you to tick the extra box to be a TCSP, whereas ICAEW for example will cover you for this automatically.

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By JRX
23rd Nov 2023 16:03

Just updated my details. Many thanks for the heads up David.

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boat
By SouthCoastAcc
23rd Nov 2023 16:11

I think I’ve had a few prompts from Icaew about this

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