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Payroll Was Not An Accountancy Service Requiring Money Laundering Registration

By Mark McLaughlin, January 2015
A payroll company was not an ‘accountancy service provider’, and an appeal against a penalty for late registration with HMRC for money laundering purposes was therefore allowed.

The appellant payroll company appealed against a penalty for a breach of the Money Laundering Regulations 2007, on the basis that it failed to register with HM Revenue & Customs (HMRC) as an ‘accountancy services provider’ (ASP). The payroll company appealed.

HMRC had written to the appellant, advising that if a payroll service was being provided they may be operating as an ASP, and if so they would need to be registered for money laundering purposes unless supervised by a specified professional body (which they were not). Following a dispute about the need for registration, the appellant registered under protest, simply to avoid further debate.

Subsequently, HMRC notified the appellant that
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