ECSH52550 - Why do the Money Laundering Regulations include Accountancy service providers

Why do the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR2017) include Accountancy Service Providers (ASPs)?

Individuals, companies and partnerships that are in business require the services of ASPs to audit their trading records, prepare accounts, complete tax returns and so on. Some individuals who may not operate a business but who are wealthy and/or have investments also use the services of those in an accountancy role.

This puts an ASP in a position where they have sight of their customer’s business records and transactions, and as such have an insight into the financial affairs of their customers. They are well placed to identify suspicious activity in their customer’s business, which may be related either deliberately or unwittingly, to money laundering.

It is for this reason that ASPs were brought within the scope of the MLR 2017. The Money Laundering Regulations 2003 (MLR 2003) required ASPs to comply with the MLRs 2003 including undertaking Customer Due Diligence procedures from 1 April 2004. However, no anti-money laundering supervisors were appointed until 15 December 2007 under the Money Laundering Regulations 2007(MLR 2007); these appointments required HMRC to act as the default supervisory body for ASPs that are not supervised by a Professional Body Supervisor.  Those ASPs were given until 1 January 2009 to register with HMRC for supervision.