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HMRC internal manual

MLR1 Penalties Guidance

Penalties guidance: the correct legal entity

Warning letters and penalty notices should be sent to the proper person for the legal entity, and where there is a different Nominated Officer it should also be copied to them.

The proper person is, for:

* a sole proprietor the Sole Proprietor
* a partnership or LLP each of the partners in the partnership
* a Limited Company or PLC the name of the company
* an unincorporated body a Trustee or authorised person



We should address warning letters and penalty notices to the legal entity itself, as named in their MLR registration.


As a general principle, any penalty action, including warning letters, must be taken against the person who is accountable within a business. (Also referred to as the accountable person)

Ultimately the person liable to the penalty is the ‘relevant person’, which is the person named in regulations 8 of the MLR 2017, who the regulations apply to. So this is who the notice should be addressed to.

To clarify, as an example, if the ‘relevant person’ is a company called J Jones Ltd,

we should address the letters to:

J Jones Ltd

When issuing warning letters and penalty notices a copy should be sent to any Accountant who is acting for the business, providing that we have authority of the business to deal with them directly for AML matters.