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HMRC internal manual

Money Laundering Regulations: Registration

Fit and Proper Test: Individuals who should have registered

There needs to be two sets of processes here:

  1. FAME processes

Registration staff check the business against the FAME database, and if no further directors or beneficial owners are shown, then they can process as normal.

If additional directors or beneficial owners are shown, then they should contact the customer advising that our records indicate that there are directors or beneficial owners in the business who have not applied for the F&P system and who are required to do so before HMRC can process their application.

Registration staff must then BF the case and monitor it for a response.

If no response is received, the application fails under regulation 29(1) (a) and we must inform the business of this in writing.

Once a response is received, then we can process all the F and P applications, and issue an education letter to the customer reminding them of their obligations to keep HMRC informed of changes of circumstance under regulation 27(4).

  1. F and P Applicants identified by Compliance staff.

When Compliance staff identify individuals who should have applied for the F and P test who have not done so, the Compliance officers should write to the business informing them that they have discovered- either as part of desk based compliance or as part of a compliance visit- additional persons subject to the F and P test. The Customer may be handed a Form MLR101 onsite by the Officer carrying out the visit, or they may be directed to the website.

The Officer should then email the Registration team advising them of this.

The Registration team must then monitor the receipt of the MLR101 and keep compliance informed.