HMRC Email Re: MLR Changes

The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (MLRs) come into force on 10 January 2020, updating the existing regulations.

HMRC guidance will be updated shortly to reflect the new regulations. It’s important that your members review the updated guidance so that they can continue to reduce the risk of their business being used to launder criminal money or finance terrorism, and remain compliant with the MLRs. While all firms will be required to be fully compliant with the new requirements from 10 January, HMRC will take into account the short lead-in time businesses have been given to implement all the new requirements in assessing the response to any non-compliance. Each case will be assessed on its own merits.

The key changes for HMRC customers include:

• Money Service Businesses and Trust or Company Service Providers who apply to register from 10 January 2020 will not be able to carry out relevant activity until their application for registration has been determined by HMRC
• Two new groups of businesses will now be supervised by HMRC and subject to the new anti-money laundering regulations. High value items can be a good way of hiding criminal proceeds and laundering money, so the regulations are being expanded to include businesses trading in art and high value letting agents.
• Letting agents which rent out property valued at 10,000 euros or more for a minimum of one calendar month.  This includes both commercial and residential property.   The online system for these Letting Agency Businesses (LABs) to register will open in May 2020.
• Those in the art market who deal in in sales, purchases, and storage of works of art with a value of 10,000 euros or more.   This may be for a single transaction or series of linked transactions, regardless of payment method used.  Art Market Participants (AMPs) can register via the online system from 10 January.

Businesses must register by 10 January 2021.

We will email businesses registered with HMRC in the next few days with more detail of the changes affecting them.

HMRC AMLS Customer Strategy & Engagement Team