Thank you for taking the time to study this guidance. It is designed to help you comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (referred to as “the Regulations” in this guidance) Meeting your legal obligations is important because it contributes to tackling the serious economic and social harm from organised crime, it also reduces the threat from terrorism in the UK and around the globe.
If you would like to know more about some of the success of UK suspicious activity reporting (SAR) see the National Crime Agency SARs annual report.
Almost all businesses supervised by HMRC for anti-money laundering purposes are subject either to fit and proper test or approval requirements under the Regulations. These requirements are to ensure that businesses’ beneficial owners and senior management are appropriate people to undertake those roles. Relevant persons must pass the relevant test before the business can register, and can remain registered, with HMRC.
HMRC stresses that neither of those requirements test whether the business is professionally run or operated. Registration is a legal requirement to trade, it is not a recommendation or endorsement of the business.
HMRC advises registered businesses to carefully avoid using language in this context that might give the impression that registration was a form of endorsement or recommendation.
There is more detail about these requirements in the fit and proper test and HMRC approval guidance.