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HMRC internal manual

Money Laundering Regulations: Registration

High Value Dealers (HVDs): Annex 1 Financial Institutions

Where a business is a high value dealer and also an Annex 1 ‘financial institution’ supervised by the FCA, the business will have two supervisors; FCA and HMRC.

The kinds of activities carried out by Annex 1 financial institutions are listed in Schedule 2 MLR 2017

An activity typically carried out by an Annex 1 financial institution is providing safe custody services. If a business is an HVD and provides safe custody services it should in effect have two supervisors. HMRC should supervise the HVD activities and FCA should supervise the safe custody services.

However we have agreed with FCA that in such cases, they will supervise the HVD activity in addition to the activity already supervised by the FCA, and the business will not need to register with HMRC as an HVD.

This means that in the example above the business will not need to register with HMRC as an HVD. It will need to register with FCA who will check that the business is complying with anti money laundering legislation in relation to both activities i.e. it will check that anti money laundering policies and procedures are in place and operating effectively when the business accepts large cash payments and when it provides safe custody services.