Anti Money Laundering - bookkeeping VAs


So it’s been a long time coming - and many, many hours of work went into this from the VAProMag team (Jo and Steph) and a little bit from myself gathering and sharing data but we’ve finally managed to get a concession for VAs offering small amounts of bookkeeping…

So basically this is for VAs with a small turnover (potentially start ups/part-time workers) who do the odd bit of invoicing/reconciliation for existing clients. NB: The work must be checked by a qualified accountant (either as you go or at year end) and you cannot advertise bookkeeping services if you claim this exemption.

Obviously it depends on your turnover, but the max bookkeeping work you’d be able to do is £125/month (5 hours?) or £1,500 a year… so it isn’t a big amount.


Thank you for the update on the AML Regulatins for VAs, extremely useful. When I contacted HMRC back in December 18 I intially rang their VAT office and was advised that only form of contact was via email for Money Laundering Supervision enquiries.

I just wanted to ask since the above update in April 19 is there a contact number now for enquiries or is it still only via the email address as outlined in the above article.

Many thanks

Philippa Pearson


Hi Philippa

These are the contacts you need:

TBH though, email is better because you get the response in writing (save it!!) - we’ve had VAs in the past who have been told on the phone they don’t need to register and then who have been fined!


Thanks to you, Jo and Steph for all the work you have done on this @caroline and it’s only because of this recent publication that I now feel confident that I don’t need to be registered and I have already submitted my declaration even thought my current registration runs until November 2019.

QUESTION I do have a question though - If I have a client who does want bookkeeping support and/or support that would warrant AML registration, can I outsource this to an associate who is AML registered. Can I still be the Lead VA?

Thanks in advance, Rachel


Good question Rachel - my understanding is that:

  1. If you advertise a bookkeeping service, you need to be registered (no concession available).
  2. If the client pays you, that counts as doing bookkeeping - a tidier way may be simply to get the client and outsourcer to work directly together, and the client comes via you for everything else (if you believe you would go over the threshold either for % of bookkeeping work done, or for turnover and you don’t want to register).
  3. You can always pay to register - and then you don’t need to worry about going over the limits.



Thank you very much for your message and also the link to the website for money laundering, much appreciated.



Virtual assistant HMRC money laundering rules.pdf (144.6 KB)


This was really useful, thank you! :+1:t2:
Can anyone recommend a distance learning provider for a level 2 book keeping qualification?


@daryl.louise I’m currently doing level 2 with Ideal Schools and they’ve been great! I’d highly recommend them.