ECSH47025 - Information containing an inaccuracy

Under Regulation 57(4)(b) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017),a business must correct any inaccuracy in information it has provided to HMRC under regulation 57(1) MLR 2017 when applying for registration or in any information subsequently provided under regulation 57(3) MLR 2017.

The inaccuracy must be corrected by the business within 30 days of it becoming aware of the inaccuracy by either, it being discovered by the business, or the business being notified of the inaccuracy by HMRC. This inaccuracy may occur before or after the registration is approved.

Example of an inaccuracy

An example of an inaccuracy could be when a business provides an incorrect business address, such as Unit 32 when the correct business address is Unit 23 (figures were transposed). In this example as soon as the business discovers the inaccuracy, or is made aware of the inaccuracy, it is obliged to make the necessary correction.

Sanctions 

If a business has failed to correct an inaccuracy within the 30 days of its discovery by the business or being notified by HMRC then the appropriate sanction should be considered.

Where information provided under regulation 57(1) and regulation 57(3) MLR 2017 is found to be false or misleading, consideration should be given to whether the risk is sufficient for the application to be refused or the registration to be suspended or cancelled – or indeed whether the case should be referred for criminal investigation.