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HMRC internal manual

MLR1 Penalties Guidance

Penalties guidance: identifying registration breaches: Regulations 26 and 33

  1. Regulations 26 and 33

Breaches of Regulations 26 and 33 - carrying out regulated activity as a MSB, HVD, TCSP, ASP or EAB without being registered with us (when HMRC is the appropriate MLR supervisor). This means trading unsupervised.

Trading unsupervised can be a very serious breach because it can indicate involvement in money laundering or an attempt to avoid applying anti-money laundering controls. This in turn may indicate that a business is being used as a vehicle for money laundering, which the business may or may not be aware of.

A breach of this Regulation will normally be identified by either:

  • disclosure, (by the business telling us) or
  • will be discovered by us during an Intervention (phone call or Compliance Visit). A visit may have been set up as a direct result of third party information we have received.

Both of these circumstances are to be treated differently. See MLR1PP5100 and MLR1PP5150