As an accountant you will be aware of the obligation to train your staff to be aware of the laws covering money laundering. HMRC advise that this training should cover anyone who deals with your customers, including the receptionist.
At the very least every member of your staff should know:
who the nominated officer is and what they are there for;
how to spot suspicious activity and report it to their senior manager or the nominated officer; and
know where to go for help about the money laundering regulations.
But are your staff aware of which of their own clients have an obligation to register with HMRC for money laundering supervision?
This includes any business in one of the following categories, if they are not already supervised by their own professional body, the FCA, or the Gambling Commission:
- art market participants (see below)
- accountancy service providers
- bill payment service providers
- company or trust service providers
- estate agents
- high value dealers
- money service businesses
- telecommunications, digital and IT payment service providers
The art market participants are only brought within the money laundering rules if they sell or purchase works of art in a single transaction, or in series of linked transactions, for €10,000 or more.
Trading in any of these sectors while not registered with HMRC (or other supervisory body) is a criminal offence, which may result in a penalty or prosecution.
The businesses in these sectors also need to register their business premises including; offices, shops, call centres, auction houses, and even cruise ships in UK territorial waters. Buildings which are only used for training employees or storing business records do not need to be registered for money laundering purposes.