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HMRC internal manual

Money Laundering Regulations: Registration

Fit and Proper Test: Convictions that are not listed in Schedule 3 of MLR 2017

Schedule 3 of MLR 2017 sets out the relevant offences that are most commonly associated with money laundering activity. However, this does not prevent HMRC from taking other convictions (non - Schedule 3 convictions) etc. into consideration, in order to assess whether an applicant is otherwise not a fit and proper person with regard to the risk of money laundering or terrorist financing.

In these circumstances you will need to establish the nature of the conviction and determine if a person with that conviction is a risk with regard to money laundering or terrorist financing. In order to make a proper assessment in cases where the offence or behaviours is not listed, it may be necessary to find out more about the circumstances of the conviction in order to carry out a proper risk assessment.

This is a broad test and issues to be considered are set out in Appendix 2 of the Fit and Proper and Approval Guidance.