Money Laundering registration - do you need to register?


A while back Jo Sparkes of VA Pro Mag worked very hard to get a definitive answer from HMRC regarding virtual assistants and the Anti Money Laundering Regulations.

We found that some VAs had been told they didn’t need to register, whilst others had been told they did - despite doing the same task for clients. HMRC’s guidance on their website is not 100% clear and Jo chased them (relentlessly!) for an answer - which we now have:

  1. Anyone advertising or doing Bookkeeping or Accountancy should be registered.
  2. If you are just transferring data to a spreadsheet or document and are not analysing the information then you are NOT REQUIRED to register under the Money Laundering Regulations.
  3. If you are creating the spreadsheets and adding the financial information on behalf of the client you are in scope and REQUIRED TO REGISTER under the Money Laundering Regulations
  4. Raising sales invoices on clients software e.g xero,sage – This would come under bookkeeping and you would be REQUIRED TO REGISTER
  5. Entering purchase invoices onto clients software e.g xero, sage. – Again this would come under bookkeeping and you would be REQUIRED TO REGISTER

I.E. If you are in any way responsible for the figures showing on the financial records of a company then you will need to be registered under the Money Laundering Regulations.

Hope that clarifies the situation! Many thanks to Jo Sparkes of VAProMag for sharing.


Dear all,

I would like to add a bit more to the above.

Can I suggest that once you send your AML registration, you wait for HMRC approval before you or your business start providing services (as per points 1, 3, 4 and 5 above listed by Caroline).

In some cases, part of the registration and approval process, HMRC requires you to apply for a “fit and proper test” too. Even if you are most experienced or qualified accountant/bookkeeper or any other finance profession.

To reach a decision, HMRC will check your information against its own records and records kept by:

• other regulatory authorities
• commercial organisations
• government and law enforcement agencies

I hope the above can help.