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HMRC internal manual

Money Laundering Regulations: Registration

Introduction: Background: General

Money Service Businesses (MSBs), Trust or Company Service Providers (TCSPs), High Value Dealers (HVDs), Accountancy Service Providers (ASPs), Estate Agency Businesses (EABs), Bill Payment Service Providers (BPSPs) and Telecommunications, Digital and IT Payment Service Providers (TDITPSPs) are covered by the Regulations and must be monitored by a supervisory authority.

If a business falls into one of the 7 business sectors, it must register with HMRC,unless it is already supervised. For example, authorised by the Financial Conduct Authority (FCA) or belong to a professional body.

MSB means an undertaking which, by way of business:

  • operates a currency exchange office (Bureau de Change);
  • transmits money or any representation of money by any means (including businesses issued with a small e-money issuer exemption certificate issued by the FCA); or
  • cashes cheques which are made payable to customers (third party cheques)

Some MSBs also act as Consumer credit institutions or as Annexe 1 Financial Institutions. See MLR2R3350 and MLR2R3400 

TCSP means a firm or sole practitioner who by way of business provides any of the following services to other persons:

  • forming companies or other legal persons;
  • acting, or arranging for another person to act -
    • as a director or secretary of a company;
    • as a partner of a partnership; or
    • in a similar position in relation to other legal persons;
    • as a trustee of an express trust or similar legal arrangement
    • as a nominee shareholder for another person other than a company listed on a regulated market which is subject to disclosure requirements
  • providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or any other legal person or arrangement;

HVD  is any business or sole trader that accepts or makes high value cash payments of €10,000 or more (or equivalent in any currency) in exchange for goods. This includes when a customer deposits cash directly into your bank account, or when they pay cash to a third party for your benefit.

This applies whether the transaction is executed in a single operation or in several operations which appear to be linked.

ASP is the term we use for:

  • Auditors who carry out statutory audit work
  • External accountants who provide accountancy services to clients
  • Tax advisers and consultants who provide advice to clients about their tax affairs
  • Payroll agents that provide accountancy services and/or tax advice
  • Customs practitioners, freight forwarders and similar businesses if they provide accountancy or tax services 

The services they provide can be recording, reviewing, analysing, calculating and reporting on financial information for other people.

EAB is the term used for businesses who carry out any activity defined as estate agency work under Section 1 of the Estate Agents Act 1979.

Estate agents are defined as a firm or sole practitioner, who or whose employees carry out estate agency work.

Estate agents work includes,

  • acting on instructions from a customer who wants to buy or sell an interest in land, in the UK or abroad, and introduce the  customer to a third party who wants to buy or sell an interest in land
  • act after such an introduction to secure the sale or purchase of the interest in land

The land can be residential or commercial.

BPSP is the term used for businesses that provide  a payment service for utility and other household bills and act on behalf of the payer.

This includes bills for:

  • gas and electricity
  • water rates and sewage charges
  • council tax payments
  • household insurance

TDITPSP is a term used for businesses that act as an intermediary between a payer and supplier of goods and services where

  • the consent of the payer to make the payment is made by any type of telecommunication, digital or IT device.
  • you receive the payment and transfer it to the supplier of goods and services as an intermediary

It is important to remember that it is only when these activities are provided ‘by way of business,’ that they fall within the scope of the regulations. See MLR2R1300