Important update on money laundering: Further advice to our readers

Significant numbers of agents have been renewing their HMRC Money Laundering Supervision registration over the past month, and as was previously reported the process is very time consuming, especially when the business has multiple partners or directors.

It can take a full day of someone’s time to collect all the information required and complete the process.

It is further complicated by the fact that you must do this through the Government Gateway which logs you out if you take too long away obtaining the information required.

This means all the previous information entered is lost unless you save it first, and saving is only permitted at certain stages!

HMRC are obviously aware of the problem and have said they are looking into it, but they say the new online registration process is a once-only process and agents will not be required to go through it annually.

Whilst technically correct, agents will each year have to check the information held by HMRC and amend and update the information. So it will not be a simple renewal process.

Apparently, a YouTube video is proposed to assist agents to complete the process, but we still await this.

The first problem you find is that you need to enter your exact company name and corporation tax unique taxpayer reference, and the system does not recognise it if you enter Ltd. instead of Limited! It took me five minutes to work that out.

You must provide confirmation of the business AML policy and procedures and the business risk assessment process, plus details of any breaches of legislation that may have taken place in the past.

One of the major time consuming parts is completing all the information required relating to shareholders, directors or partners.

A whole host of information is required, including personal information such as home address and personal tax references.

You will need to provide information on the estate agency experience the directors have and enter confirmation of the money laundering training that the directors have recently undertaken.

This can be a problem because many directors have not undertaken any money laundering training.

David Beaumont of Compliance-Matters runs EYE’s free compliance helpline on 0161 727 0798. It is available exclusively to EYE subscribers

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3 Comments

  1. Chris Wood

    For those agents who are suffering this process, spare a thought for the hundreds of franchisees who are going through it the first time having been told they didn’t need to do this and hit the point in the process where they have to declare how long they have already been trading to HMRC.

    Trading without HMRC and ICO registration is a criminal offence (as is not being a member of a redress scheme). In law, you are responsible for your own registration as a self-employed sole trader or Ltd company however, if I were a franchisee/ licensee for a certain large and rapidly expanding company, I would be a very unhappy bunny if I hadn’t received advice on the legal requirements I might need to undertake to ensure I didn’t face the possibility of a very large fine and a criminal record.

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  2. Trevor Mealham

    HMRC need to get their IT right with better guidance so agents can create a checklist pre starting the process and an auto save along the way.

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    1. Woodentop

      And of course you told them this at one of your many consultancty with them.

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