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HMRC internal manual

Money Laundering Regulations: Registration

Late Applications for Registration: When does this apply?

The Registration Team will identify that a business has failed to register at the right time when processing registration applications. If an MSB, HVD, TCSP or ASP carries out regulated activity without being registered they are failing to comply with Regulation 26 of MLR 2007. The Registration Team is responsible for issuing warning letters and penalties for failure to comply with Regulations 26 and 33. See Penalties guidance MLR1 

Failure to register at the right time will apply in the following circumstances:

  • A new business applies to register after it commenced trading.
  • Where a business has registered within a few weeks of commencing trading, see Penalties guidance MLR1 
  • An existing business did not re-register by the published date or any extended deadline but subsequently re-registers late.
  • A TCSP or ASP who was in business on 15 December 2007 did not register by the specified date, but registers late.
  • A business applies to re-register after cancellation of its registration because it did not pay a renewal fee, or for some other reasons, and trades during the period when it was not registered.