How to register with HMRC for anti-money laundering (AML) supervision

To legally operate in sectors like accountancy, tax advice, or estate agency, you must register for Anti-Money Laundering (AML) supervision with HMRC before you start trading. Registration ensures your business has the correct safeguards in place to prevent criminal activity and is a mandatory requirement that carries heavy penalties if ignored.

Who needs to register?

Not every business needs AML supervision, but if you provide certain services, it is a legal necessity. You must register with HMRC if you act as a:

• Accountancy Service Provider: Including bookkeepers, auditors, and those providing payroll services.
• Tax Adviser: Anyone providing advice about someone's tax affairs.
• Estate Agency Business: Including residential and commercial agents.
• Trust or Company Service Provider: If you form companies for others or provide registered office addresses.
• High-Value Dealer: If you handle cash payments for goods worth €10,000 or more (in a single or linked transaction).
• Money Service Business: Unless you are already supervised by the Financial Conduct Authority (FCA).

The "Fit and Proper" Test

As part of the registration, HMRC will conduct a "Fit and Proper" test or an "Approval" test on the "relevant persons" in your business. This usually includes the sole trader, partners, directors, and the nominated officer. HMRC will look at your criminal record and financial history to ensure you are suitable to run a business in a regulated sector.

Steps to complete your registration

1. Appoint a Nominated Officer: You must appoint a Money Laundering Reporting Officer (MLRO). This person is responsible for receiving reports of suspicious activity within the business and deciding whether to report them to the National Crime Agency.
2. Prepare your details: You will need your Government Gateway user ID, business address, National Insurance number, and details of your business structure (e.g., Sole Trader or Limited Company).
3. Submit the application: Registration is done online via the HMRC website. You will need to provide details about your estimated turnover and the internal controls you have in place to prevent money laundering.
4. Pay the fees: There is a non-refundable application fee, and you will also pay a fee for every premises (location) your business operates from. Additionally, there is a fee for each person who needs to undergo the Fit and Proper test.

How much does it cost?

Fees are subject to change, so always check the latest rates on GOV.UK. Typically, you can expect the following charges:

Fee Type	Description
Application Fee	A one-off fee when you first apply to be supervised.
Annual Supervision Fee	A fee paid per premises for each year you are registered.
Fit and Proper/Approval Fee	A per-person fee for HMRC to conduct background checks.

Top Tip: Don't wait until you have your first client to start this process. HMRC can take several weeks (or even months) to process an application, and you cannot legally provide regulated services until your registration is confirmed.

What happens next?

Once you have submitted your application and paid your fees, HMRC will review your information. They may contact you for further details about your business practices. If successful, you will receive a registration number. Remember, registration is not a "one and done" task; you must renew your supervision annually and keep your business details up to date with HMRC.