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HMRC internal manual

MLR1 Penalties Guidance

HM Revenue & Customs
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Penalties guidance: TCSPs/ASPs/EABs: the additional penalty: continued

There will however be exceptions to these general principles. Some TCSPs/ASPs/EABs may only act on behalf of a small number of significant clients. Under these circumstances it would not be appropriate to apply the same scale charge to a business with a small number of significant clients, as one with a larger number of small clients, paying a small fee, for limited services.

If the same scale was applied to both it could result in a penalty which was not proportionate and dissuasive because it was too low relative to the risk of money laundering by these significant clients.

In such cases therefore, when a TCSP/ASP/EAB has a small number of high paying clients, you should suspend the penalty framework and consider an alternate method of calculating a penalty. In doing so the officer should obtain advice from the team manager, and consult with the MLR Policy team on the appropriate basis for the calculation. See MLR1PP7150 and MLR1PP7160.