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HMRC internal manual

Money Laundering Regulations: Registration

Money Service Businesses (MSBs): Definition of MSB Activities

An MSB is a person who carries out one or more of the following activities by way of business:

  • Bureau de Change – that is a currency exchange undertaking, which can either be retail or wholesale. It is not necessarily in the form of a traditional bureau de change; it is the activity of exchanging sterling for a foreign currency or vice versa that creates the liability to register. (This does not include dealing with virtual currencies or changing sterling notes for different sterling note denominations).
  • Money Transmission - the transmission of money, or any representation of money (including traveller’s cheques, whether wholesale or retail) by any means, including wiring money  

Making a payment using BACS, CHAPS, SWIFT or postal order will not necessarily amount to money transmission and mean you are carrying out MSB activity. However taking cash, by way of business, and then transmitting its monetary value will amount to MSB activity, even where the transmission is by way of BACS etc.

Money transmssion does not include cash courier services (collecting money from customers and delivering to the end recipient)

  • Cashing Cheques which are made payable to customers. These are cheques which are made out by a third party and either:
    1. are made payable to the customer; or
    2. have no payee shown. In this case the name of the person cashing the cheque will have to be entered as payee. This is still a third-party cheque as it is made out by a third party for the benefit and use of the customer.

         It does not include cashing customers’ personal cheques (that is, cheques written by customers and payable against their own accounts).