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HMRC internal manual

Money Laundering Regulations: Compliance

The scope of our supervision: Introduction

To meet HMRC’s legal obligations as a supervisory authority under the MLRs 2017 and Counter Terrorism Act Officers should carry out their supervision in an effective and proportionate way in accordance with the principles in the Regulators Code. This can be found at This means that in practice it is crucial that all Compliance Teams and Individual Officers work in accordance with the following key principles:

Focus on risk

When we talk about risk we mean in terms of probability and impact:

  • Probability is the basic risk associated with the activity undertaken by the business which can increase or decrease depending on other factors such as the type of product dealt with, service used, customer type and geographic locations.
  • Impact means the potential harm that could be caused by money laundering taking place in the business. This can be indicated by the business size (turnover, number of customers and/or premises) and links with other businesses (susceptibility to being involved in ‘layering’ activity)

Officers should:

  • check and test the effectiveness of businesses’ AML controls
  • consider impact and behaviours when deciding action to be taken to address non-compliance
  • deal with non-compliance in the most effective and proportionate way

The purpose of all our compliance activity is to:

  • help businesses to understand anti-money laundering legislation
  • encourage businesses to comply with anti-money laundering legislation
  • make businesses aware of any simplified procedures and ensure that they use them

As well as guidance, webinars and e learning to increase awareness HMRC will use a range of compliance activities to do this, such as:

  • telephone or desk based interventions
  • written requests for information
  • visits to business premises
  • invitations to attend meetings in HMRC premises

These checks are generically known as interventions. Although all of the above compliance activities are strictly interventions we will normally refer to interventions by our visiting officers as compliance visits rather than desk based checks.