ECSH44125 - Premises to register

When a business registers with HMRC, it must provide details of each premises where the business carries out certain types of business and related activities covered by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulationsv 2017 (MLR 2017). A separate annual fee must be paid for each premises.

However, not all premises need to be registered. This is covered in more detail at ECSH 44175.

Premises can be defined as, but not limited to:

  • Offices
  • A location where a business trades from
  • Retail outlets, shops and auction houses
  • Call centres

Outlets

An outlet is a single location or complex which might contain several premises – for example a shopping centre or an airport (but not a city or a street). If the business has more than one business premises in an outlet at the same address, we treat the outlet as a single premises and only require one premises fee for that outlet.  

The outlets must all be managed by the business and all staff must be employed by the business. The nominated officer for the business must be responsible for all the outlets.

PO Boxes

If a PO Box is being used exclusively  as a correspondence address by a business and it has a separate premises in the UK where it carries out relevant activity, the PO box does not need to be included in the business' registration as a premises, and no fee should be raised for the PO box address. The businesscan choose to receive correspondence to the PO box address without needing to include this in its registration details as a premises.

If the PO Box address is the only premises that a business has in the UK, it must include this address as a premises in its registration details and pay the relevant fee.

Home workers

Homeworkers are considered part of the main business; the business must register one premises. The individual homes of the employers are not considered premises for the purpose of the MLR 2017, provided all the following conditions are met:

  • The home workers are employees of the business.
  • Customers contract/transact with the main business and not with the individual home workers themselves; and
  • Employees of the main business (whether based in the main premises or at home) have the same management, and work to the same policies and procedures.

Businesses trading from personal addresses

Where a business does not have a trading premises and trades from a personal address then that personal address must be registered as the business premises. However, if several BOOMs from the same business each trade from their personal address, then only one address needs to be registered (the principal trading premises), and only one premises fee is payable.

Currency exchange and money transmission machines

A business, such as a Money Service Business (MSB,) may have currency exchange and money transmission machines. The amount of premises fee payable will depend upon the location of the machine(s) as follows:

Machines located in the trading premises

Machines located within a business’ trading premises can be considered as part of that premises. The business will only be required to pay one premises fee as per HMRC’s guidance for businesses with several outlets at one address. This includes, for example, multiple machines located within the same airport or shopping centre.

Machines located away from the trading premises

Machines not located within the trading premises are considered to be a trading premises in their own right. The business must register each machine as a trading premises and pay a premises fee.

Mobile Premises

If a business uses a vehicle to trade from, then the vehicle is treated as a premises in its own right. The vehicle must be registered at the address where the vehicle is stored overnight. If the business has both a fixed trading premises and a mobile premises, then each premises must be registered, and a fee is due for each premises.

As an example, the Post Office use mobile vans in remote parts of the UK to provide a service to the public that it would otherwise have no access to. The mobile vans are stored overnight at a Post Office premises, which is also providing a relevant service to the public as a fixed premises. Each mobile van and the Post Office premises providing relevant services at which the vans are kept overnight must be registered separately.

Temporary sites

Some businesses may sometimes trade from a temporary site away from their usual trading premises. An example of this could be a High Value Dealer (HVD) conducting a remote auction for a short period of time, away from its usual trading premises, or an Art Market Participant (AMP) trading at an art fair.

This temporary site does not need to be registered if all of the following conditions are met:

  • The site is managed and controlled as one (common management control, staffing and record keeping are indicators that this is the case); and
  • The business has anti money laundering controls in place at the site.

Businesses that are trading from temporary sites must register using one of the following addresses:

  • The head office or home address (which must be registered) if the business has no trading premises; or
  • The existing principle trading premises

Cash on delivery

Businesses that accept cash on delivery are to be treated in the same way as businesses that trade through temporary sites as above. There is no requirement to include customers’ premises on their registration simply because that’s where the cash is received.