A new set of anti money laundering guides have been published on the HMRC internet site to replace Public Notice MLR8: Preventing money laundering and terrorist financing. The new guides are sector specific and provide detailed guidance in relation to the legislation, risks, record keeping and reporting requirements relevant to each business sector.
The new guides will be available on-line only. This follows on from HMRC’s announcement on 12 April 2010 that they would stop sending printed copies of Public Notice MLR8 to businesses we supervise and publish MLR8 on the internet only. All relevant businesses should now refer to the internet when they need to check anti money laundering guidance. Printed copies of the current Public Notice MLR8 Preventing money laundering and terrorist financing dated August 2008 have now been withdrawn.
The new anti money laundering guides are as follows:
- Anti money laundering guidance for Money Service Businesses
- Anti money laundering guidance for High Value Dealers
- Anti money laundering guidance for Trust or Company Service Providers
The guidance should make it easier for businesses to understand what is required of them under the Money Laundering Regulations and other legislation.
Money Service Businesses (MSBs) should note that the Counter-Terrorism Act guidance has been incorporated into the ‘Anti money laundering guidance for Money Service Businesses’ this is available at Appendix 7 of the guidance. This will assist them in complying with the terms of a direction which is a legal requirement.
MSBs should also be aware that guidance for E-money issuers will be incorporated and published in the new guidance shortly.
High Value Dealers should note that guidance on proliferation financing risks will be incorporated and published in the anti money laundering guidance for High Value Dealers shortly.
Accountancy Service Providers (ASPs) should continue to refer to the Consultative Committee of Accountancy Bodies (CCAB) guidance. HMRC are considering whether they can provide specific sectorial advice for Accountancy Service Providers on their Money Laundering Regulations website.
This would be a welcome move. Most professional bodies have already written simpler guidance than the CCAB, for the members they supervise and many will be aiming for HM Treasury approval for them. It would not seem wise to leave those in most need of simplified sector guidance with only the complex CCAB guidance to reply upon.