Money Laundering Regulations Supervision

Businesses covered by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 must be supervised for anti-money-laundering purposes. Supervision comes from one of three places: the Financial Conduct Authority (FCA), a professional body that acts as a supervisory authority, or HM Revenue & Customs (HMRC).

HMRC is the supervisor of last resort. A business in one of the sectors below that is not already supervised by the FCA or a professional body registers with HMRC instead. HMRC publishes the sectors, and the categories that do not register with it, on its own guidance page.

HMRC publishes the following business sectors as needing to register with it under the regulations:

• money service businesses not supervised by the FCA
• high value dealers handling cash payments for goods totalling 10,000 euros or more
• trust or company service providers not supervised by the FCA or a professional body
• accountancy service providers not supervised by a professional body
• estate agency businesses
• bill payment service providers not supervised by the FCA
• telecommunications, digital and IT payment service providers not supervised by the FCA
• art market participants buying or selling works of art valued at 10,000 euros or more
• letting agency businesses renting property valued at the equivalent of 10,000 euros or more a month

HMRC states that a business already supervised by the FCA, or by a professional body that acts as a supervisory authority, does not register with HMRC as well. The professional bodies HMRC names include:

• Association of Accounting Technicians
• Association of Chartered Certified Accountants
• Chartered Institute of Management Accountants
• Institute of Chartered Accountants in England and Wales
• Law Society
• General Council of the Bar
• Council for Licensed Conveyancers
• Insolvency Practitioners Association

HMRC lists further professional bodies alongside these. The full list, and the wording of each category, is on HMRC’s guidance page.

HMRC also publishes categories of charity and public sector body that do not register with it:

• UK registered charities that provide these services free or for a nominal charge
• public authorities serving members of the public free of charge, or for a fee to cover the cost of providing the service only
• public authorities that provide these services as part of their statutory duties and charge a fee
• public authorities that are funded by the Exchequer or council tax payers, and not by the person who receives the service
• public authorities or joint ventures (where 50% or more of the shares are owned by the public body) that provide services only to other public authorities
• public authorities or joint ventures (where 50% or more of the shares are owned by the public body) that provide services to a firm authorised by a public body to act on their behalf, for example a housing association

Registration is handled directly by HMRC. Its guidance sets out who needs to register, when, and how:

• HMRC: Money laundering supervision, who needs to register (opens in a new tab)

Orchard72 does not handle money laundering supervision registration on anyone’s behalf. Registration and supervision are managed entirely by HMRC, the FCA, or the relevant professional body.

This requirement appears in the regulatory requirements section of your professional dashboard. If one of HMRC’s published categories applies to your practice, you can record the requirement as not applicable and cite the category you are relying on.

We record the category you cite. We do not check it against HMRC, and recording it here is not confirmation from HMRC or from any supervisor that it covers you. Your declaration is a statement about your circumstances now, so we ask you to confirm it again each year.

Orchard72 is a technology marketplace that connects users with legal, financial, and tax professionals. We do not provide legal, tax, or regulatory advice.

We report published regulatory requirements as a courtesy to help professionals stay informed. This is not advice, and professionals should always verify their supervision position directly with HMRC, the FCA, or their professional body.

• HMRC: Money laundering supervision, who needs to register (opens in a new tab)
• Financial Conduct Authority: money laundering and terrorist financing (opens in a new tab)