HMRC AMLS Visit Support

KYC / AML Services

HMRC AMLS Visit Support

Expert preparation, on-the-day support and remediation for every
business supervised by HMRC under the Money Laundering Regulations.

HMRC AMLS Visit Support

Notice of an HMRC anti-money laundering (AML) compliance visit is one of the most important moments in the life of a regulated business. How well you prepare can decide whether the outcome is a clean closing letter, an action plan, a financial penalty, or a threat to your registration. At acumengcompliance.com, we make sure you are ready.

HMRC is the AML supervisor for a wide range of UK businesses registered under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs). As part of that supervision, HMRC checks compliance through visits to your premises or office-based checks, such as a phone call or desk-based review. Officers look at how your risk assessment, policies, controls and procedures actually operate, review your records and speak to the people responsible. A visit does not necessarily mean HMRC thinks something is wrong, but it does mean your controls must work in practice, not just on paper. Our HMRC AMLS Visit Support service prepares you for exactly that.

What is at stake

HMRC can issue financial penalties, publish statements censuring a business, suspend or prohibit individuals from management roles, suspend or cancel a registration, seek a court injunction and refer cases for criminal investigation. HMRC publishes details of the penalties and sanctions it issues. In one published case, a London money service business was fined £1.4 million for failing to carry out risk assessments, maintain appropriate controls and conduct proper due diligence. Trading while unregistered is a criminal offence.

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COMPLETE COVERAGE

All 9 HMRC-Supervised Sectors at a Glance

HMRC is the AML supervisor for nine business sectors, where the business is not already supervised by the FCA or a professional body. We support every one of them, including the sub-sectors shown below.

Money Service Businesses (MSBs)

High Value Dealers (HVDs)

Trust or Company Service Providers (TCSPs)

Accountancy Service Providers (ASPs)

Estate Agency Businesses (EABs)

Letting Agency Businesses (LABs)

Art Market Participants (AMPs)

Bill Payment Service Providers (BPSPs)

Telecom, Digital and IT Payment Service Providers (TDITPS)

Beneficial owners, officers, managers and the nominated officer must pass HMRC’s fit and proper test (MSBs and TCSPs) or approval check (other sectors) before registration. MSBs and TCSPs must not trade until registration is confirmed.

OUR CORE SPECIALISM

Payments & Money Services

The payments sector sits across two regulatory regimes. HMRC supervises many money service businesses for AML purposes, while the Financial Conduct Authority (FCA) registers or authorises payment and e-money firms under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Knowing exactly which regulator oversees what is essential, and it is an area where businesses frequently get caught out. We support every type of firm in this space.

Who supervises what: a quick guide

Business type

AML supervisor

Payment / e-money permission

Bureau de Change (Currency Exchange) and cheque cashing

HMRC

Not normally required for these activities alone

Money remitter registered as an SPI

HMRC

FCA registration (Payment Services Regulations 2017)

Money remitter authorised as an API

HMRC*

FCA authorisation (Payment Services Regulations 2017)

EMI or small EMI

FCA

FCA authorisation or registration (Electronic Money Regulations 2011)

Pawnbroker authorised by the FCA for consumer credit only, offering MSB services

HMRC (for MSB activity)

FCA authorisation for consumer credit

Firm authorised under FSMA that also carries on MSB activity (other than the case above)

FCA

FCA authorisation

* This applies to money transmitters that solely provide payment services. Where a firm carries on additional FCA-regulated activities, such as issuing e-money, the FCA may become its sole AML supervisor. Supervisory arrangements depend on each firm’s exact permissions, so we confirm your position at the outset.

MSB

Money Service Businesses

Money transmission, currency exchange and cheque cashing. HMRC supervises MSBs that are not supervised by the FCA, applies a fit and proper test to beneficial owners, officers and managers, and MSBs must not trade until registration is confirmed. Money transmitters must also be registered or authorised by the FCA.

BUREAU DE CHANGE

Bureau de Change (Currency Exchange)

High-street currency exchange, travel money counters and kiosks, and online foreign exchange. We focus on cash-intensive risk, linked transactions and structuring, identification at the counter, and sanctions screening.

SPI

Small Payment Institutions

Registered with the FCA under the Payment Services Regulations 2017. Money transmitters that solely provide payment services as an SPI are supervised by HMRC for AML, so the firm answers to both regulators and its HMRC and FCA records must match.

API

Authorised Payment Institutions

Authorised by the FCA under the Payment Services Regulations 2017. Money transmitters that solely provide payment services as an API are supervised by HMRC for AML, while the FCA authorises their payment services. We prepare you for HMRC scrutiny across your principal and agent network.

EMI

Electronic Money Institutions

Authorised EMIs and small EMIs under the Electronic Money Regulations 2011 are supervised by the FCA for AML, not HMRC. Where an EMI also carries on activity in an HMRC-supervised sector, dual supervision rules apply. We support EMIs with AML framework reviews and supervisory readiness for either regulator.

PRINCIPALS & AGENTS

Agent Networks

Principals are responsible for the AML compliance of all their premises and agents, including training and applying their policies. Every agent address must appear on the HMRC registration. We deliver agent audits, training, onboarding files and oversight frameworks that stand up to review.

EVERY HMRC-SUPERVISED SECTOR

Other Industries We Support

If your business is registered with HMRC for AML supervision, we can help. Our specialist sectors are highlighted in gold.

HVD

High Value Dealers

Businesses accepting or making cash payments of €10,000 or more for goods, in a single transaction or linked transactions. This can include jewellers, gold and bullion dealers, and watch, car and machinery dealers.

PROPERTY

Letting Agents

Letting agency businesses handling residential or commercial lets where the rent is €10,000 or more a month for a let of a month or longer. They register as an estate agency business with letting as a sub-sector. We cover landlord and tenant due diligence and source of funds checks.

PAWNBROKING

Pawnbrokers

Pawnbrokers are authorised by the FCA for consumer credit. Where they also offer MSB services such as currency exchange, cheque cashing or money transfer (often as an agent), they register with HMRC for that activity. Those making high-value cash sales of goods should also check the HVD rules.

PROPERTY

Estate Agents

Residential and commercial estate agents, including relocation agents and property finders acting for buyers, and property abroad. We focus on due diligence on both parties and beneficial ownership.

PROFESSIONAL SERVICES

Trust or Company Service Providers

TCSPs not supervised by the FCA or a professional body, such as company formation and registered office providers. Key people must pass HMRC's fit and proper test, and TCSPs must not trade until registered.

PROFESSIONAL SERVICES

Accountancy Service Providers

External accountants, bookkeepers and tax advisers that are not supervised by a professional body.

ART

Art Market Participants

Dealers, galleries, auction houses and intermediaries in art transactions of €10,000 or more, and operators of freeports storing works of art.

PAYMENTS

Bill Payment & Telecom, Digital and IT Payment Providers

Bill payment service providers and telecommunications, digital and IT payment service providers that are not regulated by the FCA.

Planned change for TCSPs and Accountancy Service Providers

The government has confirmed that the FCA will become the single AML supervisor for professional services, including TCSPs and accountancy service providers currently supervised by HMRC. The transfer requires new legislation and has not yet taken effect, so HMRC remains the supervisor for now. We will help you prepare for the move when it happens.

INSIDE THE VISIT

What HMRC Examines

Every intervention is different, but officers commonly focus on the areas below and expect to see clear evidence for each.

Area

What officers expect to see

Business-wide risk assessment

A written assessment specific to your customers, products, services, countries, delivery channels and transactions, reviewed regularly.

Policies, controls and procedures

Proportionate controls approved by senior management that match what staff actually do day to day.

Customer due diligence (CDD)

Identity verification, beneficial ownership, purpose of the relationship and a risk rating for each customer.

Enhanced due diligence (EDD)

Extra checks for politically exposed persons, high-risk third countries and complex or unusually large transactions, including source of funds and wealth.

Ongoing monitoring

Transaction monitoring, identification of linked transactions and structuring, and periodic customer reviews.

Suspicious activity reporting

A competent nominated officer (MLRO), internal reporting, SARs to the National Crime Agency and awareness of tipping off.

Sanctions and funds transfers

UK financial sanctions screening and, for money transmitters, complete payer and payee information on transfers.

Record keeping

Records retained for at least five years after the relationship or transaction ends, and retrievable on request.

Training and governance

Training records showing who was trained, when and on what; a named senior manager responsible for AML compliance; independent audit where appropriate.

Registration accuracy

Up-to-date premises, agents and responsible persons, consistent with the FCA register where relevant.

LESSONS FROM THE FIELD

Common Failings We Help You Avoid

Businesses rarely fall short in an HMRC visit because they ignore the rules altogether. More often it is because of gaps that are easy to overlook until an officer asks the question. Typical examples include:

A generic risk assessment copied from a template rather than written for the business.
Policies that do not reflect what staff actually do at the counter or online.
Incomplete identification, beneficial ownership or source of funds records.
Linked transactions or structuring that monitoring did not pick up.
No evidence of staff training, or an MLRO unsure of their responsibilities.
Agent oversight that exists on paper but not in practice.
HMRC registration details, premises or agent lists that are out of date or inconsistent with the FCA register.

END-TO-END SUPPORT

How We Support You

01 – Before the visit

Preparation

Pre-visit health check and gap analysis against the MLRs and HMRC guidance
Review or rewrite of your risk assessment, policies and procedures
Sample testing of customer files, CDD and EDD records
A visit-ready evidence pack organised the way HMRC expects
MLRO and staff briefing, plus a mock HMRC interview

02 – During the visit

On the day

03 – After the visit

Remediation

Analysis of HMRC's findings letter
A prioritised remediation action plan with clear owners and dates
Drafting your response, and support with an HMRC review or tribunal appeal if you disagree with a decision
Ongoing compliance support so you are ready for the next intervention

WHY US

Why Businesses Choose Us

Deep sector expertise

Hands-on experience across MSB, SPI, API, EMI, Bureau de Change (Currency Exchange), HVD, letting agency, pawnbroking and every other HMRC-supervised sector.

Plain-English, practical guidance

Controls and documents your staff can actually follow, not generic templates that fall apart under questioning.

Complete lifecycle support

From HMRC registration and first-time compliance to visit preparation, remediation and ongoing support.

Fast turnaround

HMRC notices often come with short deadlines. We act quickly so you are never unprepared.

Received an HMRC AML visit letter?

Don’t leave it until the week before. Contact our team today for a confidential consultation and a pre-visit health check tailored to your business.

+44 7852 806969

info@acumengcompliance.com

1 Canada Square, Canary Wharf Estate, London E14 5AA, UK

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What is at stake

Get a Free Quote

COMPLETE COVERAGE

All 9 HMRC-Supervised Sectors at a Glance

Money Service Businesses (MSBs)

High Value Dealers (HVDs)

Trust or Company Service Providers (TCSPs)

Accountancy Service Providers (ASPs)

Estate Agency Businesses (EABs)

Letting Agency Businesses (LABs)

Art Market Participants (AMPs)

Bill Payment Service Providers (BPSPs)

Telecom, Digital and IT Payment Service Providers (TDITPS)

OUR CORE SPECIALISM

Payments & Money Services

Who supervises what: a quick guide

Business type

AML supervisor

Payment / e-money permission

Bureau de Change (Currency Exchange) and cheque cashing

HMRC

Not normally required for these activities alone

Money remitter registered as an SPI

HMRC

FCA registration (Payment Services Regulations 2017)

Money remitter authorised as an API

HMRC*

FCA authorisation (Payment Services Regulations 2017)

EMI or small EMI

FCA

FCA authorisation or registration (Electronic Money Regulations 2011)

Pawnbroker authorised by the FCA for consumer credit only, offering MSB services

HMRC (for MSB activity)

FCA authorisation for consumer credit

Firm authorised under FSMA that also carries on MSB activity (other than the case above)

FCA

FCA authorisation

MSB

Money Service Businesses

BUREAU DE CHANGE

Bureau de Change (Currency Exchange)

SPI

Small Payment Institutions

API

Authorised Payment Institutions

EMI

Electronic Money Institutions

PRINCIPALS & AGENTS

Agent Networks

EVERY HMRC-SUPERVISED SECTOR

Other Industries We Support

HVD

High Value Dealers

PROPERTY

Letting Agents

PAWNBROKING