The Scope of Money Laundering Regulations: Registration: Business has more than one Supervisor
Where a business is a high value dealer (HVD) and also an Annexe 1 “financial institution”(http://www.hm-treasury.gov.uk/d/moneylaunderingregulations2007.pdf) (as listed in Schedule 1 MLR 2007) supervised by the FSA, the business should have two supervisors: FSA and HMRC. For example, a car dealer supervised by the FSA for the financing of commercial transactions or for financial leasing. However, we have agreed with FSA that they will supervise any HVD that is already supervised by FSA for their financial activities and the business will not be required to register with HMRC as an HVD.
In the same way, where a business supervised by FSA is an accountancy service provider (ASP) and is not already supervised by a named professional body listed in Appendix 1 of MLR9 it should have two supervisors: FSA and HMRC. However, we have agreed with FSA that they will supervise the ASP activities and the business will not be required to register with HMRC as an ASP.
We have agreements with FSA that where HMRC and FSA would both be supervisors for a business, FSA will supervise them and they will not need to register with us. This means that the only businesses that must register with us are:
- money services businesses (MSBs) and high value dealers (HVDs) unless they are already supervised by FSA,
- and accountancy service providers (ASPs) and trust and company service providers (TCSPs) that are not already supervised by FSA or a professional body.