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HMRC internal manual

Money Laundering Regulations: Compliance

Accountancy Service Providers (ASPs): Compliance Visits to ASPs

A compliance visit to an ASP is different from a visit to an MSB, HVD or TCSP because with these other sectors officers are examining the risks of money laundering and terrorist financing in the relationship and transactions entered into between the business and its client. For example if an HVD business accepts a cash payment of £20,000 for the sale of goods, it is that direct transaction between the customer and the HVD that has to be risk assessed by the HVD for money laundering purposes.

An ASP might, for example, carry out accountancy work for a client and charge a fee of £1,000 for the work done. It is not this transaction that has to be assessed for money laundering purposes. Instead, the ASP has to view the client’s business affairs and make an assessment of the risk that in the conduct of its business, the client is not involved in money laundering activity.