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HMRC internal manual

MLR1 Penalties Guidance

Penalties guidance: registration penalties: introduction

Because failing to register a business with us at the correct time or failing to update their registration details will not itself automatically expose anything to money laundering activity, a simplified penalty framework for registration breaches has been adopted.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)  MLR1PP12160 

Even when there is no suspicion of money laundering, registration breaches are likely to indicate that there are also weaknesses in a business’s anti-money laundering controls, and other regulatory breaches may have also occurred. When more significant breaches are identified at a subsequent compliance visit, any penalty for these breaches will be calculated separately and in addition to any registration penalties.

We may issue a warning letter on the first occasion a business fails to update their registration details but a warning letter is not appropriate if a business fails to register at the correct time.

If a new business fails to register before it starts to trade and makes a full unprompted disclosure they will be sent a pre penalty letter advising the business of our intention to issue a penalty based on the minimum fixed fee and any unpaid fees. If we receive a late registration or re-registration following a reminder from us we will treat this as a prompted disclosure.

Penalties for late registration identified at the time an application for registration is received will be issued by an officer from the registration team. If late registration is identified during the course of a compliance visit the late registration penalty will be issued by the officer conducting the visit.