HMRC, as a ‘designated authority’ (Money Laundering Regulations 2007 (SI 2007/2157), reg. 36(b)) may impose penalties ‘of such an amount as it considers appropriate’ on a tax adviser who fails to comply with the following requirements of the regulations:

(1)applying due diligence measures;

(2)ongoing monitoring;

(3)identification of customer before the business relationship established or occasional transaction carried out;

(4)ceasing to act if unable to apply due diligence measures;

(5)enhanced due diligence;

(6)keeping records;

(7)establishing and maintaining appropriate policies and procedures;

(8)providing appropriate training for employees;

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