HMRC enforcement guidance

HMRC’s civil measures for money laundering supervision (HMRC’s guidance) sets out how HMRC will use its civil and criminal enforcement powers under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692. Practitioners will also find the HMRC—Economic Crime Supervision Handbook useful when advising on this topic.

HMRC’s approach to enforcement—general approach

HMRC’s approach to enforcement is risk-based and has three strands:

1. •

   to promote compliance by engaging with businesses and helping them to put in place appropriate controls to counter the threat that they may be used by criminals to launder money or fund terrorism

2. •

   to prevent noncompliance by making sure that businesses’ processes and interactions with customers help them stay on the right side of the law. HMRC will challenge high-risk businesses and those with inappropriate controls

3. •

   to respond to noncompliance by treating noncompliant businesses in a way that encourages sustained compliance in future

HMRC’s