ECSH43030 - Verifying if a business is registered in the United Kingdom

When considering if a business should be registered for anti-money laundering (AML) supervision in the United Kingdom (UK), it is important to understand where the responsibility for the day-to-day management of the relevant activity is carried out as per Regulation 9. It is not relevant where the actual work of a business is being carried out, where the owners live, or where the customers are based.  For more information see ECSH43000 - Carrying out business in the United Kingdom.   

A business carrying out relevant activity in the course of business in the UK must be registered for AML supervision by one of the UK AML supervisors. For more information see ECSH42525 - By way of business.   

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

If it is clear that a business is based in the UK and the day-to-day management of the business is based in the UK, you can carry on with the case as usual as the business is in scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).  

If the business is not being operated from the UK, and there is no UK footprint at all the business is out of scope of the MLR 2017, even if there are UK customers. 

If it is unclear where the business is based and where the day-to-day management of the business takes place, then you should send a further information letter to gather more information which will allow you to make a decision if the business is out of scope of the MLR 2017. Whilst these enquiries are ongoing, Compliance Officers should continue with their intervention.