HMRC introduces money laundering register for unqualifieds

Sgt Pike
if only it was like Dads Army rather than the SS - i dont suppose you remeber 'tomorrow belongs to me' (Cabaret) thats what i was getting at setting one self up to rule the world to the exception of everyone else view point on the basis that you are superior

absolutely unracist but certainly anti faschist

OK so my spelling isnt great but my sentiments are sound, and if you dont understand that thats a pity

and by the way i love Scotland my mum was born in the gorbals

do you work for HMRC?!

Silly Boy indeed
this has nothing to do with Scotland or Ayr in particular its all about Aryian

Would this work?
My wife works as a self employed book-keeper at two clients premises - so that's 2 X £95 for them and 1 X £95 for our office here.
It must be cheaper for her to join a professional Association and be covered under their auspices..
Oh how I need to win the £1m premium bond draw and ditch this lunacy!

Doing it for free

Andrew

If you derive no fees from your 'self-employment' then you are not engaged in it "by way of business" and so are not subject to the requirements of MLR 2007.

This is rather different from the situation where a person makes their living as a self-employed book-keeper but does a bit of work for which he does not charge. If that bit of free work is part of the activities of his self-employment then, in my opinion, it is done "by way of business" and the MLR 2007 will apply to it.

David
www.MLROsupport.co.uk

Home Address
Doug

I believe that bookkeepers who offer their services on a commercial basis must register, presumably those who work at a clients site will need to register giving their home address as their "office"?

Unfair
This annoys me. Not the fact that there is some form of registration, but the fact that we have to stump up £95!

I work full time for a top 10 firm and have 15 years experience. I help out a few friends for a minimal fee as they cannot afford to use a decent sized firm.

There is no way I am going to pay £95 when I only generate a few hundred pounds a year in fees! This simply means that I will no longer be able to help those friends and they will have to do the tax returns themselves - which I would not recommend!

Does this registration requirement apply even if I take no fees for the work I do? For example - assisting with my brothers tax return?

What a nanny state we have become..

Bookkeeper exempt?
Looking at the proposed rules it is possible a bookkeeper who only did a bit of work on your and other people's premises might be exempt.

The fee applies to a business premise so if there is no business premise surely no fee?

HMRC try to define premises which could include a cruise ship apparently but they don't mention whether houseboats, caravans or tents might be considered premises - or the boot of your car.

Not an Option
I would be pleased to employ either bookkeeper as would the clients, but neither is willing to work on an employed basis. The amounts that they earn are very small and they both appear to feel that it isn't woth the effort, can't be sure how much of this feeling relates to regulation, possibly they are using the regulation as an excuse

The key word is 'employ'.
Chances are you will need to employ bookkeepers under a proper contract of service to get away from MLR.

NeilW

Will Bookkeepers become extinct?
The first effect of this legislation, to those accountants not involved in money laundering or terrorism, will be a further reduction in the availability of external bookkeepers. We have two clients who use freelance bookkeepers for their Sage bookkeeping and payroll work. Both of these ladies have just a handful of clients and see their remuneration as "pin money", both intend to give up rather than register. Registering with HMRC appears to fill bookkeepers with dread, strange when you consider they are already registered with HMRC for SA.

Maybe we will all be able to employ more bookkeepers, time will tell, but a further reduction in the availability of bookkeepers is a serious concern.

Euan
is it another unhappy day?

i am irish you must forgive a paddy!

i think you meant something else - if i am right what is it?

Registered offices and company formation

David

You are quite correct that an accountant who is to be supervised by HMR&C for money laundering regulation compliance and who also provides, by way of business, registered office or correspondence address or company formation services (the full list of services is in Regulation 3(10) MLR 2007) also has to register as a "trust or company service provider" with HMR&C at an additional fee. This involves a "fit and proper" test - in other words a check for past criminal convictions, an undischarged bankruptcy, or similar (see Regulation 28 for more detail).

However an accountant who is supervised in relation to MLR compliance by any body other than HMR&C (such as ICAEW, ACCA, AAT, ATT, FSA, ICB, IFA, etc) is not required to register with HMR&C as a "trust or company service provider" since that part of his operations also falls under the supervision of his existing supervisory body. The wording in support is in Regulations 23(d)(iii), 25(1)(c) and 28(1) MLR 2007.

David
www.MLROsupport.co.uk

P.S. A copy of the Money Laundering Regulations 2007 can be found online at
www.opsi.gov.uk/si/si2007/uksi_20072157_en_1.

These are the Regulations as originally passed, there have been some amendments to them since but these are minor.

Additional Fees if you provide other services
In addition to the £95 annual registration fee, if you provide Registered Office facilities, and/or provide company formation services and/or company secretarial services, there is an additional fee of £50, which entitles you to a "fit and proper test".

The "fit and proper test" ensures that you are known to HMRC, as they will verify you with the following information, which you are required to supply - your NINO, Passport Number (if you have one) UTR Number, VAT Registration Number, Bank Details -

No doubt at some stage all this information will be backed up onto yet another CD disk - and distributed at a later date, to the general public at large.

Incidentally when I first enquired about the "fit and proper test" back in early December, the HMRC helpline I spoke to, did not actually realise or appreciate accountants got involved in forming companies, or acting as a registered office, or providing company secretatial duties.

Registration date for all of the above was 15th December 2007.

unqualified??
Your leader on the new register from HMRC leads me neatly to highlight what I consider to be a real failure of the various accounting bodies. I for example, a qualified accountant work for a firm ( Ltd Co ) that does not fall within the remits currently set out by the accounting bodies. I cannot personally gain a Practising Cert ,and in fact do not need one,and as such remain working in that apparently dark world of unregulated.

That is fine, as far as I am concerned and as far as the business for whom I work is concerned we are happy that we provide a high quality service that I try to ensure equates with that provided by my in practice colleagues.

Why though do not the bodies such as ICAEW and others sort this out and make an opening for such firms rather than leave us in the cold?

Surely it is not beyond the wit of the recognised bodies to take on this registration process rather than leave it to HMRC.

What we will now have is the profession of accountancy becoming ever more split into smaller and smaller sectors - this cannot be good. It also of course gives those unregulated a nice certificate and a claim to be " regulated by HMRC " something even ICAEW and others cannot do!!

I await the next registration body and yet another certifcate for £95 - rather like University Degrees being handed out by unregistered universities from ... a qualified accountant!

Would that be Aryan ?
.....................unable to spell.......................

welcome to the Ayrian youth HMRC branch
.....................unable to trade.......................