Notification requirement: Penalties for failure to send notification: Appeal consideration
Notification Regulations: Penalties for not sending a notification: Appeal consideration
HMRC will look at the systems and processes in place to ensure that notifications have been sent to the correct clients. Where it is clear that little or no effort has been made, the penalty is likely to be due.
Where the Specified Financial Institution or Specified Relevant Person has taken all reasonable steps to put in place processes to identify the right clients and to send them a notification, then it is unlikely a penalty will be charged, even where some clients are missed out or extra ones included. Each case will be considered on its own merits.