The Scope of Money Laundering Regulations: Registration: ASPs that are covered by the MLRs but do not need to register
Although they carry on relevant business and are required to follow anti money laundering policies and procedures, ASPs falling within the category below are not required to register with us:
Firms or sole practitioners acting as ASPs, when all their customers are ASPs that are supervised by HMRC or by a professional body listed in Schedule 1 of MLR 2017 providing:
- They do not deal directly with the customer of the supervised firm(s);
- They are included within the scope of the AML policies, controls and procedures of the supervised firm(s), including suspicious activity reporting and training programmes; and
- Both businesses provide evidence in the form of a written contract to confirm that the arrangement covers compliance with all the AML requirements in respect of the entire customer relationship.