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HMRC internal manual

Money Laundering Regulations: Registration

Money Service Businesses (MSBs): Retailers who accept Foreign Currency and give change in Sterling

In the majority of cases currency exchange is an incidental feature of the transaction and the retailer is not liable to register.

However, if the transaction takes place in such a way that the act of exchange results in the payment of commission or profit for the service, by way of business, See MLR2R1300, then this constitutes the activity of a money service business and therefore creates a liability to be registered.