HMRC Anti Money Laundering Guidance


HMRC have produced the results of their thematic review into AML Compliance in the MSB sector

The market currently looks as follows;




Total MSB sector



Of which do Currency Exchange

1178 (64%)

20,941 (47%)

Of which do Money Transfer

  990 (53%)

28,790 (65%)

Of which do Cheque cashing

   445 (24%)

  2,386 (5%)


Interestingly in 2010 there were 3585 firms but only 42,738 stores. They found there were examples of good and bad practice in the relationships between principals and agents and encouraged firms to fully understand the ML Regulations 2017, to follow the HMRC guidance, and to always apply a risk based approach.

HMRC have now produced the full Guidance for Money Service Businesses as promised. The report is very helpful and covers their expectations and ‘must do’s’ in terms of;


-Senior Manager Responsibility

-Risk Assessments and policies

-Customer Due Diligence

-Money Transmitters Obligations

-Reporting Suspicious Activity

-Staff training

-Principal=Agent Relationships

-Risk indicators for each type of MSB


The report is available at 


Both reports are available in the NPA members web area and we have an AML module in our online training provision, contact NPA for further details