Application for registration

Failed the fit and proper purpose test

Case Law – Hunt [2015] TC 04183

Application of due diligence measures

Beneficial owner

Commentary – Indirect Tax Reporter ¶60-888

Due diligence measures

Commentary – Indirect Tax Reporter ¶60-885

Enhanced due diligence

Commentary – Indirect Tax Reporter ¶60-887

Generally

Commentary – Indirect Tax Reporter ¶60-883

Ongoing monitoring

Commentary – Indirect Tax Reporter ¶60-884

Reliance on third parties

Commentary – Indirect Tax Reporter ¶60-889

Requirement to cease acting

Commentary – Indirect Tax Reporter ¶60-890

Simplified due diligence

Commentary – Indirect Tax Reporter ¶60-886

Definitions

Money laundering

Commentary – Indirect Tax Reporter ¶60-881

Terrorist financing

Commentary – Indirect Tax Reporter ¶60-881

Enforcement

Appeal from review of HMRC decision

Commentary – Indirect Tax Reporter ¶60-907

Criminal offences

Commentary – Indirect Tax Reporter ¶60-908

Penalties for advisers supervised by HMRC

Commentary – Indirect Tax Reporter ¶60-905

Powers of HMRC as designated authority

Commentary – Indirect Tax Reporter ¶60-904

Review of HMRC decision

Commentary – Indirect Tax Reporter ¶60-906

Enhanced due diligence

Client not met in persons

Commentary – Indirect Tax Reporter ¶60-887

Generally

Commentary – Indirect Tax Reporter ¶60-887

Politically exposed person

Commentary – Indirect Tax Reporter ¶60-887

Generally

Commentary – Indirect Tax Reporter ¶60-881

High value dealer

Case Law – S L Wines Ltd [2015] TC 04720

Penalties on high value dealer for breaches of regulations

Case Law – Elliott Knight Ltd [2018] TC 06338

Penalty for failure to register

Case Law – Blackhorse Property Management Ltd [2016] TC 05449 ; Payedoc Payroll Services Ltd [2014] TC 03832 ; Thames Valley Payroll Ltd [2014] TC 04063

Penalty for non compliance with anti-money laundering rules

Case Law – N Bevan Ltd [2016] TC 05404

Policies and procedures

Commentary – Indirect Tax Reporter ¶60-899

Record-keeping

Commentary – Indirect Tax Reporter ¶60-898

Relevant persons

Commentary – Indirect Tax Reporter ¶60-882

Sole practitioners without staff: no need for MLRO

Commentary – Indirect Tax Reporter ¶60-899

Supervision

HM Revenue and Customs

Commentary – Indirect Tax Reporter ¶60-903

Professional bodies as supervisory authorities

Commentary – Indirect Tax Reporter ¶60-902

Requirement to register

Commentary – Indirect Tax Reporter ¶60-901

Training

Commentary – Indirect Tax Reporter ¶60-900

Wholesaler of spirits in bond for cash

Case Law – S L Wines Ltd [2015] TC 04720