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HMRC internal manual

Money Laundering Regulations: Registration

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.legislation.gov.uk/uksi/2017/692/pdfs/uksi_20170692_en.pdf (as listed in Schedule 2 MLR 2017) supervised by the FCA, the business should have two supervisors: FCA and HMRC. For example, a car dealer supervised by the FCA for the financing of commercial transactions or for financial leasing. However, we have agreed with FCA that they will supervise any HVD that is already supervised by FCA 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 FCA is an accountancy service provider (ASP) and is not already supervised by a named professional body , it should have two supervisors: FCA and HMRC. However, we have agreed with FCA that they will supervise the ASP activities in addition to the activity already supervised by the FCA, and the business will not need to register with HMRC as an ASP.

We have agreements with FCA that where HMRC and FCA would both be supervisors for a business, FCA 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 FCA,
  • accountancy service providers (ASPs) and trust or company service providers (TCSPs) that are not already supervised by FCA or a professional body
  • bill payment service providers (BPSPs) and telecommunication, digital and IT payment service providers (TDITPSPs) that are not supervised by the FCA or one of the professional bodies
  • estate agency businesses (EABs) not supervised by the FCA