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Anti-Money Laundering Regulation update

Friday 03 November 2017

It's been a busy couple of weeks in the world of anti-money laundering, with the release of the revised National Risk Assessment and changes to the supervision fee structure.

Here, we have broken down the recent changes to help minimise the impact on your business.

Anti Money Laundering Supervision fees

Since the introduction of the new Money Laundering Regulations back in June, HMRC have undertaken a number of additional responsibilities as an AMLS supervisor. In light of the recent changes, and in order to ensure their effectiveness as a supervisor, HMRC have reviewed their fee structure.

The changes – what you need to know

HMRC is now required to carry out a new approvals test, checking key personnel for relevant criminal convictions - a charge of £40 per test has been introduced for this, commencing 1 November 2017. This fee is only for businesses not previously subject to fit and proper testing, including Accountancy Service Providers (ASP), Estate Agency Businesses (EAB) and High Value Dealers (HVD) and is a lifetime fee which covers routine retesting.

The annual renewal fee for all businesses, will increase by £15 (from £115 to £130 per premises) from 1 December 2017. The full list of AMLS fees will be:

  • £40 approval fee (for ASPs, EABs and HVDs only)
  • £130 renewal fee per premises
  • £100 application fee for new customers (this is unchanged)
  • £100 fit and proper test fee for Money Service Businesses and Trust or Company Service Providers (this is unchanged)

Fees are calculated and paid at the point of submission. However until the AMLS online service is updated, the approval test fees will be added after submission and customers will be contacted directly to sign in and pay this.

HMRC will be conducting a review, consulting in early 2018, on how fees might change in the future. For more information about the changes and the new Money Laundering Regulations 2017, visit GOV.UK.

National Risk Assessment

HM Treasury and the Home Office have published a second National Risk Assessment (NRA), which follows the 2015 NRA and looks at the UK’s money laundering and terrorist financing risks. 

The key risks in the estate agency sector identified in the 2015 NRA were: criminals and professionals using estate agents to help buy and sell property to launder funds; complicit estate agents helping criminals buy or sell property, sometimes in conjunction with other complicit professionals; perceived low understanding of money laundering and terrorist financing risks in the sector, and low compliance with the MLRs.

Whilst the document points out that agents themselves are low risk, property continues to be an attractive vehicle for criminal investment, particularly for high-end money laundering.

Read the document here

Help is available!

NAEA Propertymark want to get you up to speed as quickly as possible, that is why our free to attend Masterclasses will focus on anti-money laundering changes for the remainder of 2017. We have also added new dates for our Financial Crime Update course, and are introducing a brand new online course for 2018 which provides an introduction to anti-money laundering.

HMRC will also be running a number of webinars throughout November, which offer an overview of what agents will need to do under the Money Laundering Regulations:

  • Accountancy Service Providers - Tuesday 14 November 2017 at 9.00am
  • Trust or Company Service Providers - Tuesday 14 November 2017 at 11.00am
  • Estate Agency Businesses - Wednesday 15 November 2017 at 12.30pm
  • Money Service Businesses - Wednesday 15 November 2017 at 14.30pm 

You can watch the webinar on Suspicious Activity Reports (SARs) here