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HMRC internal manual

Money Laundering Regulations: Compliance

Legislation: Specific failings and breaches of the Counter Terrorism Act

During compliance checks on MSBs officers should check that they have included how to deal with directions issued under the Counter Terrorism Act 2008 in their anti money laundering systems and processes.

Failure to do this will be an offence under the MLR 2017 Regulation 19 - failure to establish, maintain, monitor and manage the required risk based policies and procedures.

Officers should also ensure that MSBs comply with the specific requirements of a direction issued under the Counter Terrorism Act 2008 and the specific requirements of a condition of a licence under paragraph 17.

Failure to do these may result in a civil penalty under Schedule 7 paragraph 25

A person commits an offence under paragraph 30(1) if they fail to comply with a requirement imposed by a direction.