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United KingdomGOV.UK

HMRC details when to close money-laundering checks it cannot complete

HMRC caseworkers gain rejection, deregistration and cancellation routes where money-laundering compliance cannot be tested, including Watchlist, ETMP and regulation 59(1)(e) steps.

By Taxxa AI OyPublished 12 November 2026

Financial Sector & Markets

Industry: Across industries

HMRC-supervised businesses whose money-laundering compliance cannot be tested must not receive a compliant outcomeGOV. Where officers cannot check compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) — for example a business that cannot be traced and looks missing, or one that registered in error and is not a relevant person — caseworkers must not issue a closure or advice letterGOV. They must agree the outcome with their line manager and, where needed, the Operational Technical Specialist Team. A case can meet rejection criteria after initial review under the project initiation document, or managers can agree the risks are gone with no further action to take.

Where law-enforcement or other HMRC action blocks progress, caseworkers must agree with their line manager and other stakeholders whether to close the enquiry or run a parallel investigation. For authorisations cases, the application must still be determined under regulation 59GOV, which permits refusal for unmet requirements, false information, unpaid penalties or charges, reasonable supervisory opposition, or suspected future failure to meet MLR 2017, Terrorism Act 2000 Part 3 or Proceeds of Crime Act 2002 Parts 7 and 8 duties.

Where contact attempts suggest the business no longer exists — numbers dead, emails bouncing, new occupiers at the premises, owners untraceable — caseworkers must discuss the evidence with their team leader and consider Watchlist entries. Where the business has ceased trading with no one available to speak to, the team-leader discussion is again required, with a possible intervention with a former officer under HMRC powers.

Where the business still trades but stopped relevant activity, the last 12 months decide the routeGOV. If it was a relevant person within that period, the check continues over the relevant activity done, establishing why activity stopped and whether all relevant requirements were met. If it never carried out relevant activity, caseworkers must understand its activities, registration reason and other risks, review the Standard Information Package, weigh a desk-based rather than face-to-face intervention with manager agreement, and secure G7 compliance-lead approval for any change from the project initiation document. They must confirm with sector single points of contact, line manager and the Operational Technical Specialist Team that registration is unneeded, ask the business to deregister, monitor the enterprise tax management platform, record it in the case management system and trackers, and clear open-form blocks via Authorisations contacts. The business receives a letter explaining why supervision is unneeded and confirming deregistration, warning that starting relevant activity as defined by MLR 2017 requires registration without delay.

A business staying registered while not currently a relevant person — for example one planning to start within 12 months — still has its risk assessment, policies, controls and training records reviewed, with no customer due diligence to test absent relevant transactions or relationships. Compliant documents lead to a closure or advice letter, otherwise a warning letter. Documents showing it will not comply point to cancellation on regulation 59(1)(e) suspected-future-breach groundsGOV, with regulation 59(1)(b) false-information grounds also available. Intelligence-led packaged cases continue as usual. Where a business stops communicating, regulation 66 powers to require information, documents or attendance apply only with grounds to suspect it is or was a relevant person, payment service provider or connected personGOV. Where HMRC delay or officer error makes pursuing identified breaches reputationally impossible, the outcome is agreed with the manager and Grade 7 with the sector strategy lead.

Legal basis: The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulations 59, 60 and 66 with Schedule 6Legislation.

If your compliance check cannot be completed, agree the rejection, deregistration or information route with the caseworker promptly and confirm your registration status so the case is closed correctly.

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