Money Laundering Regulations... help!! - The Book-keepers Forum (UK)

debzinkent · Veteran Member

Money Laundering Regulations... help!!

Amanda · Expert

HI,

YOu will need to register with HMRC, the cost is about £120 per year. I think you can do it on line.

HTH

debzinkent · Veteran Member

And do I have to do anything as far as compying to them goes, it all looks complicated on the HMRC website.

YLB-HO · Guru

Have you thought about contacting the IAB? Depending on how part qualified you are with the AAT, they may give you exemptions at the Associate or Member level? At both levels they will let you apply to practice and be monitored by them. You can then find out what you need to do to comply from them. Its all about "knowing your client and their businesss".

ICBUK · Guru

Hi Debbie,

By the sounds of it you are already registered with the ICB, so the HMRC wont supervise you (well they may take your money but your registration would be void).

Contact the ICB (you can ask for me) for advice.

Stardoe · Guru

When I registered with the ICB as a Student I was already working as a self-employed bookkeeper, and they were able to issue me with a Supervision Licence to cover me for MLR. Can't remember the exact cost now, but was something in the region of £70 ish, which is cheaper than HMRC.

Pauline

Julies bookkeeping · Veteran Member

James I find your answer a bit confusing, she is not qualified, yet you are saying she is covered for MLR, no mention of needing a practise certificate.

What you have said about HMRC is also confusing, as I was led to believe that the practise certificate is what we need for MLR, if we have this no need to register with HMRC if we do not have this we can register?

I would like to get to the bottom of this before my certificate runs out, as I do not want to pay for this if it is not needed.

Shamus · Forum Moderator & Expert

Hi Julie,

if you are not a member of a supervisory body and you register directly with HMRC then there is no need for a practicing certificate.

If you have a practicing certificate through a supervisory body then your MLR is implied by such membership so there is no requirement to register with HMRC.

However, as an aside, if you are a member of a supervisory body without a practicing certificate then the rules of the supervisory body mean that you cannot register with HMRC so you must in such instance have a practicing certificate through them and registering with HMRC when you are a student member is not an option.

As memntioned above though, there are instances where student members may be entitled through their supervisory body to apply for a supervision licence.

Hope this helps until James is able to fill out any gaps in the morning.

All the best,

Shaun.

Wella · Expert

I was under the impression that a student member of the ICB couldn't obtain a practice licence, and as a member (student, or otherwise) of the ICB you couldn't be a self employed bookkeeper without a practice licence? Or have I missunderstood the rules?

ICBUK · Guru

Hello all,

Well it's complicated because the HMRC have a rule that says you cannot register with them for MLR if you are registered with another supervisory body (eg the ICB etc).

So if you are a student with the ICB, or other supervisory body, the HMRC class this as being registered with another supervisory body, and therfore you cannot register with the HMRC for MLR.

Obviously this is not normally an issue, unless someone who is working as a self employed bookkeeper wants qualifications, and registers with the ICB on a course. Their supervision with HMRC becomes void, and so they have to cease work whilst they study.

So to fix this problem, the professional bodies allow a temporary supervision license to be granted to a student during their study. Then, when they have passed the required examinations they can upgrade to membership and take out a Practice License.

This temporary supervision license is not a Practice License, and does not come with any of the PL benefits or support, and does not allow the student to mention they are registered with the ICB, or use its crest etc.

There are some other restrictions, like time and number of attempts at the examinations etc.

This is not available to members, as they need the full Practice License, it is only for self employed bookkeepers trying to join the ICB via study, and for obvious reasons cant give up their clients during this time.

Shamus · Forum Moderator & Expert

Hi Bill,

pretty sure that we are in complete agreement with each other there.

Its either you are with the ICB and have MLR through them or your on your own and register through HMRC. You can't sign up for the ICB as a student but set yourself up as a bookkeeper before you have a practice certificate as the MLR would not be valid as it wasn't given by your supervisory body.

The supervision licence is for some quite specific cases and is given to students at the discretion of the ICB. There have been a couple of people on here who have spoken about supervision licences in the past but I can't remember from which posts. Maybe James will fill out the detail on that later.

Talk in a bit,

Mutley

ICBUK · Guru

Hi Shamus,

think we crossed posts here smile

but your very right, its not normal and only came about because some people didn't like being registered with HMRC so wanted to join the ICB for the extra support.

Shamus · Forum Moderator & Expert

Hi James,

Cheers for clearing that up.

all the best,

Shaun.

debzinkent · Veteran Member

Thanks for the advice regarding MLR. However, now I'm worried that as I'm only part qualified with AAT and haven't yet embarked on the ICB course, although I am currently studying ICB Payroll Management Course, does this mean that I can't work as a self-employed book keeper anyway??

ICBUK · Guru

Hi,

If you are working as a self employed bookkeeper you need the MLR Supervision License.

As you are only a student you would need the temporary license I mentioned. Call me on 0845 060 2345 if you like to discuss your actual situation. You should also call the AAT as I am pretty sure they do a student temporary license too.

ICBUK · Guru

Oh should mention you only need 1 license from 1 body, not both.

lutherparker · Veteran Member

-- Edited by lutherparker on Sunday 8th of January 2012 04:42:51 PM

Shamus · Forum Moderator & Expert

Hi Luther,

welcome to the forum.

but of course it's not just about MLR cover.

Being a member of a supervisory body ensures that you meet a certain level of proficiency in your chosen field.

There are a lot of bookkeepers out there with no qualifications some of whome give a bad name to the rest of us. By making people pass certain exams before they are allowed to practice and by keep testing members throughout their careers via continued professional development the bodies are giving a better name to all bookkeepers as a whole because there is an expectation off a certain level of skill.

I've had disagreements with supervisory bodies myself and some of the rules can be seriously frustrating, but at the end of the day I really think that we are better as a profession with than without them.

The point about work. At the end of the day they are not recruitment agencies but they do sometimes advertise roles for which generally there are far more interested parties than roles available.

As to whether ICB membership will get you through the door for a permanent role, that's a whole different debate that has been discussed often and at length on the site.

By the way, my response is meant by way of discussion, not arguement. You're points are valid but there is another side to the arguement which I've tried to convey until James is back on the site to put the ICB's perspective.

kindest regards,

Shaun.

kjmcculloch83 · Expert

Luthor,

I think the difference between my ICB membership (AICB PM.Dip) and Practice Licence and the cost of registering for MLR with HMRC is about £30. That is ICB are £30 more expensive. Are the services offered by ICB worth £30? I think they are. Many on here will know that, like Shaun with professional bodies, I have not always seen eye to eye with ICB. I don't find their support particularly useful, I think any questions I have are answered much more comprehensively on here.

I get an advert on their site, and use of the logo which in itself I would say is worth the £30. Is it a selling point for me? I'm not sure, but its certainly not a drawback. They now have discount card, I use one for my fuel and food shopping. It saves me about £5 per week. All in all I think that ICB actually pays me just over £250 per year to be a member.

Just in case James reads this, that's not an invitation to increase my fees.

Kris

lutherparker · Veteran Member

-- Edited by lutherparker on Sunday 8th of January 2012 04:41:54 PM

Shamus · Forum Moderator & Expert

Afternoon Kris,

Of all the people to rush to our white chargers in James defence who would have thought that it would have been us two!

I know that I'm no longer a member but I think that the work that James has been putting in to taking the profession forwards for the benefit of all deserves a bit of recognition from all bookkeepers regardless as to whether they are ICB members or not.

Anyway, I neither agree totally not disagree totally with Luther. The HMRC route is right for some but not others.

If people are very experienced then HMRC is an alternative but there are a lot of bookkeepers just setting out down this path for whom going down that route would be ill advised and ICB, IAB or AAT membership is a good way of ensuring that bookkeepers meet a minimum expected level of competence before being let out on an unsuspecting and nowe very litigous public.

Shaun.

ICBUK · Guru

kjmcculloch83 wrote:
All in all I think that ICB actually pays me just over £250 per year to be a member.

News article title I think biggrin

Thanks both for your kind words

Shamus wrote:

If people are very experienced then HMRC is an alternative but there are a lot of bookkeepers just setting out down this path for whom going down that route would be ill advised and ICB, IAB or AAT membership is a good way of ensuring that bookkeepers meet a minimum expected level of competence before being let out on an unsuspecting and nowe very litigous public.

I disagree, not entirely as there will be some bad eggs who decide to steal, or some who can pass exams with 100% but have no 'real life common sense', however it is much better to have standards than non, and most of those examples would be picked up before long.

I regularly see people being rejected for ICB membership, not only if they have no idea about bookkeeping, but for criminal records such as theft, assult, murder and even peodophilia!

These 'bookkeepers' then go and register with another body and carry on working.

Jackbrown · Member

Money laundering refers to the process of concealing the source of illegally obtained money. So there is no need to qualify through recognised organisation if you have enough knowledge then it is OK. I think Amanda is right you have to register with HMRC.