Who Must Firms Register With for Anti-Money Laundering Purposes?
The United Kingdom has a prescribed framework in place to combat money laundering and the financing of terrorism. Firms operating within various sectors are required to register with appropriate regulatory or supervisory bodies to ensure compliance with Anti-Money Laundering (AML) regulations. This article outlines the primary authorities that firms must register with for AML purposes in the UK and the specific obligations these registrations entail.
Who Needs to Register?
The specific firms that need to register for AML purposes can vary, but they generally include financial institutions, non-financial businesses, and certain financial advisors and item dealers.
- Examples of financial institutions that need to register include banks, credit unions, insurance companies, investment firms and money service businesses (MSBs).
- Non-financial businesses which also need to register include high-value dealers (goods over £10,000), law firms, real estate agents, accountancy service providers, and casino operators.
- Certain professionals outside of the previous two sectors which are required to register include financial advisors and planners, gemstone dealers, art and antique dealers, and virtual asset service providers (VASPs).
Who Must You Register With?
Solicitors Regulation Authority (SRA)
Law firms and solicitors in the UK are supervised for AML purposes by:
- The Solicitors Regulation Authority (SRA),
- The Law Society,
- The Law Society of Scotland or
- The Law Society of Northern Ireland.
These supervisory bodies require law firms to comply with AML regulations, including conducting customer due diligence, keeping detailed records, and reporting any suspicious transactions.
Registration with these bodies is mandatory if you meet certain criteria, and firms must demonstrate robust AML controls and procedures.
To register with the SRA, you must either log in to your existing SRA account, create an account if you’re new, or activate your account using an activation code.
The Association of Chartered Certified Accountants (ACCA)
Accountants and accountancy firms are subject to AML oversight by professional bodies, including:
- The Association of Chartered Certified Accountants (ACCA),
- The Chartered Institute of Management Accountants (CIMA),
- The Institute of Chartered Accountants in England and Wales (ICAEW) and
- The Institute of Chartered Accountants of Scotland (ICAS).
These bodies require their members to register, comply with AML regulations, and maintain effective AML systems. This includes conducting due diligence on clients, monitoring transactions, and reporting suspicious activities to the relevant authorities.
Financial Conduct Authority (FCA)
The Financial Conduct Authority (FCA) is the principal regulatory body overseeing AML compliance for a broad range of financial institutions in the UK. Registration is completed through the FCA’s “Connect” application portal. Firms that must register with the FCA include:
- Banks and building societies
- Investment firms
- Financial advisers
- E-money institutions
- Payment institutions
- Cryptocurrency businesses
The FCA requires these entities to implement rigorous AML policies and procedures, conduct customer due diligence (CDD), and report any suspicious activities. Registration with the FCA involves submitting detailed information about the firm's operations, ownership, and AML controls. Firms must also undergo regular audits and inspections to ensure ongoing compliance.
HM Revenue & Customs (HMRC)
HM Revenue & Customs (HMRC) is responsible for overseeing AML compliance for certain non-financial businesses and professions that are not overseen by other bodies such as the FCA. Firms that need to register with HMRC include:
- Money service businesses (MSBs)
- High-value dealers
- Art market participants
- Estate and letting agents
- Accountancy service providers
- Trust or company service providers (TCSPs)
These businesses must register with HMRC, adhere to AML regulations, and implement effective AML programs, including risk assessments, staff training, and reporting suspicious activities.
The Gambling Commission
Businesses in the gambling sector, such as casinos and betting operators, must register with the Gambling Commission for AML purposes. The Gambling Commission mandates that these firms implement comprehensive AML policies, conduct customer due diligence, and report any suspicious activities.
We Help Firms Stay Compliant in the Fight Against Money Laundering
At PDA Legal, we understand the importance of robust and timely AML controls to combat the risks that money laundering poses. Our comprehensive in-person training services provide support to firms in their responsibilities within the AML framework. Get in touch with us today to book a FREE AML consultation.
