Abiding by money laundering regulations is a serious business to say the least. Early last month a money service business (MSB), based in Luton, UK was fined £23.8 million by the UK HMRC (the supervisor for MSBs) for ‘significant breaches’ of AML legislation. There are no rights of appeal.

The offences occurred between July 2017 and December 2019 relating to:

  • carrying out risk assessments;
  • incorrect policies, controls and procedures;
  • conducting due diligence; and
  • record keeping.

Money service businesses offer customers the ability to remit cash, exchange currencies and cash cheques quickly and easily without the need to rely on banking facilities. They would be deemed to high risk operations.

A quick examination of the company’s latest accounts to 30 November 2019 shows balance sheet net assets of £154,824 and cash at bank of over £680,000, so the ability to pay this fine is not that obvious.

Watch out for our 2021 update to the AML Policies & Procedures Manual coming soon.

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