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HMRC internal manual

Money Laundering Regulations: Registration

Refusing an Application for Registration: Change to Fit and Proper Status

We must consider cancelling a registration if the circumstances relating to the:

  • applicant,
  • person who directs the business,
  • beneficial owner,
  • or nominated officer’s,

fit and proper status have changed and the person is no longer considered fit and proper.

We will write to the business notifying them that the individual’s fit and proper status has changed. The business can replace the individual or remove the individual to a position within the business where they are no longer relevant individuals for the purposes of the fit and proper test. Details of individuals removed or replaced must be sent to us within 14 days. The business will need to complete a new fit and proper application form and pay a fee where the individual is replaced.

If the business decides to do nothing we must cancel their registration.

For a sole proprietor, the consequences of a change to the fit and proper status are slightly different.

  • As an individual: He will not be able to undertake any role in any business, including his business, which requires him to pass the fit and proper test.
  • As a business: As he (as a sole proprietor) is no longer considered fit and proper person the business cannot continue to be registered.

We will write to the sole proprietor giving him 14 days to let us know if he does not agree that his fit and proper status has changed. We must cancel the registration if a sole proprietor is not a fit and proper person.