ECSH40545 - Group Structures: Which businesses must register

Requirement for businesses within a group structure to register 

Only businesses within a group structure that engage in relevant activity must be registered for anti-money laundering supervision. Each separate legal entity must be registered in its own right unless it is acting as an agent. Further guidance on agent registrations is available in ECSH44425 - Agent guidance.

If a business within a group structure does not engage in relevant activity, there is no requirement for that business to be registered for anti-money laundering supervision. 

Unless the parent company in a group structure is engaging in relevant activity, it does not need to be registered for anti-money laundering supervision. 

Guidance on group structures that extend overseas is available in ECSH43040 - Group structures that extend overseas

Beneficial owners 

While the parent company may not be required to register for anti-money laundering supervision, the beneficial owners of the group will need to be included as relevant persons in any application to register the groups’ subsidiaries who undertake relevant activity. For further guidance on whether beneficial owners should be included in a business’ application to register with HMRC for anti-money laundering supervision, see ECSH 45791 - Who needs to be declared as a responsible person? Introduction