Anti-Money Laundering Regulations

If as a virtual assistant you regularly offer bookkeeping or accountancy services you must register for Anti-Money Laundering Regulations.

Please note, if you have to sign in to a client’s accountancy software to send out invoices or add information, you will either need to register for AMLR, or you will need to apply for the exemption below.

However, if as a virtual assistant the financial services you provide account for less than 5% of your business turnover, then you may meet the criteria for an exemption.  This doesn’t mean you don’t have to act, you still have to apply for this exemption, and we will walk you through this below.

Before I go into details, I want to say a massive thank you to both the Society of Virtual Assistants and Joanne Sparkes of VA Pro Magazine who worked tirelessly to make HMRC understand the role of the virtual assistant and worked with them to come up with the VA exemption.  For this, everyone in the industry is very, very grateful!

IMPORTANT:  If you meet the criteria for an exemption, do not register and pay first, we have come across several virtual assistants who have done it this way round, and they were not given a refund for any payments they had previously made to HMRC.

So, if you meet the criteria below, then you can apply for an exemption.

  • Working as a Virtual Assistant is your main business. 
  • Your annual business turnover is not more than £30,000.
  • No more than 5% of your total business turnover applies to accountancy service activity.
  • The accountancy services you provide support your main business.
  • There is no other business activity you need to register under Money Laundering Regulations.
  • Your work is reviewed by an accountant or bookkeeper who is registered for money laundering supervision.

(This criteria is taken from https://www.gov.uk/guidance/money-laundering-regulations-accountancy-service-provider-registration)

 

Should you meet the above criteria, then you will need to apply for the exemption.  And in order to do this, you will need to send an email to MLRCIT@hmrc.gov.uk and provide them with the following information…

  • A declaration of how your business meets each of the criteria.
  • Details of your business.
  • A contact name.
  • Your main business address.
  • Contact email address.
  • Contact telephone number.

(This criteria is taken from https://www.gov.uk/guidance/money-laundering-regulations-accountancy-service-provider-registration)

We have an email template you can use for this here.

When I applied for this exemption, I received a response within 24 hours.  You will need to keep a copy of your email, in case you need to refer back to it in the future.

After a week or two, you should receive a response from them telling you that you are exempt.  Once again, keep a copy of the response, in case you need to refer back to in the future.

Sometimes HMRC gets in contact with virtual assistants who are exempt, to organise a visit, this is to ensure that the qualifying conditions are being met and adhered to and that nothing has changed. I know a couple of virtual assistants now who have had a visit from them, so it does happen, but they are very kind and often work with the virtual assistant improve their processes.

If I the future you decide to take on more accountancy work or bookkeeping services, then you will have to let HMRC know as it may push you outside the criteria for the exemption.

Fines are hefty for anyone who doesn’t register or apply for an exemption and are caught carrying out accountancy or bookkeeping services, so don’t get caught out.  Clients are also getting savvier about what their VA’s should be signed up to, so you may be questioned if you don’t register, yet are offering the services.

For more information or to register, visit https://www.gov.uk/guidance/money-laundering-regulations-who-needs-to-register