Money laundering supervision for accountancy service providers
Find out if you're an accountancy service provider who needs to register with HM Revenue and Customs (HMRC) under Money Laundering Regulations.
Who should register
You may have to register with HMRC if your business operates as an accountancy service provider.
Under Money Laundering Regulations accountancy service providers are:
- auditors who carry out statutory audit work
- accountants who provide accountancy services to clients
- tax advisers and consultants who provide advice to clients about their tax affairs
- payroll agents that provide accountancy services and/or tax advice
- customs practitioners, freight forwarders and similar businesses if they provide accountancy or tax services
The services they provide can be recording, reviewing, analysing, calculating and reporting on financial information for other people. This includes:
- professional bookkeeping services
- accounts preparation and signing
- giving a customer specific tax advice, for example:
- help with completing and submitting tax returns or duty claims
- advice on whether something is liable to a tax or duty
- advice on the amount of tax or duty that is due
If you provide these services virtually or through an automated service, you will still need to perform customer due diligence on your customer
If you do some but not all of these things, and you’re still not sure, you can contact HMRC for guidance.
Who doesn’t need to register
You don’t need to register if you:
- are an Insolvency Practitioner (you’ll be supervised by the Insolvency Service)
- give tax advice or accountancy services on a non-commercial basis, for example within your own organisation rather than to a third party
- give customers, or link to, basic tax information that would be the same for everyone (like the basic rate of income tax)
Payroll businesses that don’t need to register
If you’re a payroll services provider to a third party, you’re not an accountancy service provider for the purposes of the Money Laundering Regulations if you:
- provide software or hardware service support for payroll data processing, as long as you don’t analyse or prepare any financial information
- pay invoiced service fees to self-employed people, umbrella companies, partnerships or other corporate service providers
- operate as a body like an umbrella company or a managed service company and carry out payroll functions for employees who are working on assignments for an end-user client
- provide recruitment or human resources management services and carry out payroll functions as a small part of your main business activity (for example, you might be an employment business that supplies or manages temporary or contract workers)
Customs practitioners that don’t need to register
If you’re in business as a customs practitioner, a freight forwarder or similar, you’re not covered by the Money Laundering Regulations if you only provide services like:
- helping your clients with classifying or valuing exports and imports for customs purposes
- helping clients to comply with customs and other procedures, like using simplified declaration procedures or facilities like warehousing
- helping clients with import or export licensing, and submitting import and export declarations on their behalf
- paying duties, taxes and levies on behalf of importers
Accountancy service providers already registered or supervised elsewhere
If you’re an accountancy service provider you must register with HMRC unless:
- you’re already supervised for Money Laundering Regulations purposes by a professional body
- all your customers are themselves supervised by HMRC or a professional body
The main supervisory bodies
For Money Laundering Regulations, the main supervisory bodies for accountants, bookkeepers, tax advisers and other financial advisers are the:
- Association of Accounting Technicians
- Association of Chartered Certified Accountants
- Association of International Accountants
- Association of Taxation Technicians
- Chartered Institute of Management Accountants
- Chartered Institute of Taxation
- Financial Conduct Authority
- Institute of Certified Bookkeepers
- Institute of Chartered Accountants in Ireland
- Institute of Chartered Accountants in Scotland
- Institute of Chartered Accountants of England and Wales
- Institute of Financial Accountants
- International Association of Bookkeepers
- Law Society
If you’re supervised by one of these bodies you don’t need to register with HMRC.
If all your customers are accountancy service providers
If all your customers are accountancy service providers supervised by HMRC or a professional body, you don’t need to register so long as:
- you don’t do business directly with the supervised accountancy service providers’ own customers
- you’re included in the supervised accountancy service providers’ anti money laundering controls and procedures, suspicious activity reporting, and training programmes
- you have a written contract with each of your customers confirming that every aspect of the relationship between you meets all anti money laundering requirements
You need to meet all of these conditions, otherwise you’ll need to register.
How to register
At the end of each registration period we’ll send you a renewal notice inviting you to renew your registration by paying the annual fee on all your listed premises. If you don’t need your registration to continue then you should notify HMRC.
If you don’t pay the correct renewal fee then HMRC may terminate your registration and remove your business from its anti-money laundering register.
Published: 25 February 2014
Updated: 26 June 2017
- Updated guidance to explain that providers who have virtual or automated services may need to register but providers who only give generic, basic tax information may not.
- Content reviewed and updated to simplify the registration process.
- First published.