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HMRC internal manual

Money Laundering Regulations: Registration

Incorrect Information on the Register: Compliance Action

MLR businesses have an obligation to tell us about any change in registration details within 30 days of the change occurring, as set out in Section 8 Registration Notice MLR9

While on a visit or a phone call, Compliance Officers should check that the MLR business details match those on the register. If a Compliance Officer identifies changes to a business’s registration details, which have not been notified to us, the Compliance Officer will need to establish:

  • The changes that have taken place; and
  • When these changes happened

In many cases a failure to notify a change in registration details will be the result of error or neglect. The information may have been miskeyed at registration. The business may have provided the wrong information on registration, or have not updated their registration details.

If the business provided the wrong information on registration you will need to consider if this was the result of:

  • A genuine mistake;
  • A challenge to the policy; or
  • A deliberate attempt to provide false or misleading information

Compliance Officers will:

  • Confirm the full, correct details;
  • Establish and record the reason for failure to notify on time;
  • Write to the MLR business, asking them to confirm the details to the Registration Team within 30 days of the date of the issue of the letter otherwise they could incur a penalty; and
  • Make a written report to the Registration Team, including a copy of their letter to the business

If you believe that the business has deliberately provided false or misleading information, you should consider referring the case to RIS using form MLR145.