ECSH48585 - Cancelling a money service business agent - when to contact a principal

Introduction

A business registered with HMRC for anti-money laundering supervision can appoint another business to act on its behalf as an agent. The business that is registered with HMRC is referred to as a principal and any business that it appoints to act on its behalf is its agent. Further guidance on the principal-agent relationship is available in ECSH44425.

Some money service businesses (MSBs) will apply to register with HMRC in their own right while continuing to act as an agent of another MSB. For example, an MSB that acts as a money transmission agent may apply to register with HMRC as a currency exchange provider in its own right.

When you cancel the registration of an MSB due to the determination that a business or its beneficial owners, officers or managers (BOOMs) are not fit and proper (F&P), you should establish if the business acts as an agent of a principal MSB and send a letter to the principal firm advising that its agent’s registration has been cancelled due to failing the F&P test. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

When you cancel the registration of an MSB for reasons unrelated to the F&P test, and that MSB also acts as an agent of a principal MSB, you should not notify the principal of the cancellation.

How to establish if an MSB acts as an agent

You should search the Financial Conduct Authority (FCA) Financial Services Register to establish if a business is acting as a money transmission agent. You should also inspect HMRC’s supervised business register to determine if the business you are refusing currently acts as an agent of a principal MSB that is supervised by HMRC. (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Further guidance on the cancellation process is available in ECSH48582.

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