Having spent some really fun time on the HMRC website I came across the following:
"If you are an Accountancy Service Provider you must register with HMRC unless....all your customers are themselves supervised by HMRC or a professional body "
So the way I read this is that if my only clients are already authorised under the FSA (and the sole director is authorised under the FSA), and therefore supervised for moneylaundering under the FSA themselves, then I do not need to register as an accountancy service provider with HMRC.
What this mean is that if you are registered with a professional body such as ACCA ( see below for the list, I copied from HMRC website) then you don't have to register with HMRC.
Accountancy Service Providers already registered or supervised elsewhere
If you are an Accountancy Service Provider you must register with HMRC unless:
* you're already supervised for Money Laundering Regulations purposes by a professional body * all your customers are themselves supervised by HMRC or a professional body
The main supervisory bodies
For the purposes of the Money Laundering Regulations the main supervisory bodies for accountants, bookkeepers, tax advisers and other financial advisers are:
* Association of Accounting Technicians * Association of Chartered Certified Accountants * Association of International Accountants * Association of Taxation Technicians * Chartered Institute of Management Accountants * Chartered Institute of Taxation * Financial Services Authority * Institute of Certified Bookkeepers * Institute of Chartered Accountants in Ireland * Institute of Chartered Accountants in Scotland * Institute of Chartered Accountants of England and Wales * Institute of Financial Accountants * International Association of Book-keepers * The Law Society
If you're supervised by one of the bodies above you don't need to register with HMRC. You can find a full list of supervisory bodies in Appendix 1 of the HMRC leaflet MLR9, 'Registration Notice for Accountancy Service Providers'.
If all your customers are Accountancy Service Providers
If all your customers are Accountancy Service Providers who are supervised by HMRC or a professional body you don't need to register so long as you meet all of the following conditions:
* you don't do business directly with the supervised Accountancy Service Providers' own customers * you're included in the supervised Accountancy Service Providers' anti-money laundering controls and procedures, suspicious activity reporting, and training programmes * you have a written contract with each of your customers confirming that every aspect of the relationship between you meets all anti-money laundering requirements
Thanks Manoj. The conditions you cite (the 3 last starred points above) - where do these come from? - can you point me to the place on the HMRC website if applicable.
