Money laundering supervision: the fit and proper test
Find out about the checks applying to money service businesses and trust or company service providers.
The fit and proper test is a series of checks carried out by HM Revenue and Customs (HMRC) to make sure that you and certain people involved in running your business meet the requirements of the Money Laundering Regulations.
You must be included as a responsible person and pass the fit and proper test if you’re:
- the sole proprietor of the business
- a partner in the business
- a director of the business or a nominated officer
- a trustee or a shareholder who owns or controls more than 25% of the shares or voting rights in the company
When the test takes place
HMRC will carry out checks using the information you supply online when you apply to register for anti-money laundering supervision.
If a new responsible person joins your business after you’ve registered online you should sign in to the online service and add their details.
If you’re not yet registered online for anti-money laundering supervision and you want to add another responsible person who:
- has not passed the fit and proper test previously, complete and send form MLR101
- already has fit and proper status, complete and send form RCT1
HMRC will check the accuracy of the information you provide online.
This will include checking those details against information held by us, other regulatory authorities, government and law enforcement agencies.
We will contact you if we need you to send additional information or documents to confirm identification.
If you pass the test, HMRC will continue to monitor your fit and proper status.
We won’t register your business if any of the applicants fail the test.
If you fail the test
If you can’t satisfy HMRC that you’re a responsible person regarding the risk of money laundering or terrorist financing you’ll fail the test.
We’ll ask for evidence of your honesty and integrity to prove you can understand and fulfil your obligations under the regulations.
To reach a decision we’ll consider a range of information including whether you:
- are being investigated or have been convicted of money laundering or other offences involving dishonesty, fraud or financial crime
- have been disqualified from acting as a company director
- have been subject to a confiscation order under the Proceeds of Crime Act 2002
- have a track record of consistent non-compliance with the Money Laundering Regulations, or with the EU Payments Regulation which applies to money transmission service providers
- have been disciplined or expelled by another supervisor or professional body for regulatory or professional failings