Bureau de Change

UK bureau de change businesses are supervised for AML purposes by HM Revenue & Customs (HMRC).
Firms must register with HMRC before trading, including registering the business itself, each set of trading premises, and the individual appointed as MLRO or AML responsible person.

Once registered, bureau de change businesses are required to operate to strict AML standards under the UK Money Laundering Regulations and to maintain effective AML arrangements on an ongoing basis. Firms must also ensure their HMRC AML registration and certification remain accurate and up to date, including notifying HMRC of any material changes.

HMRC expects bureau de change firms to be able to demonstrate:

• A firm-wide risk assessment tailored to currency exchange activity
• Clear, documented AML policies, controls and procedures
• Robust customer due diligence (CDD) and enhanced due diligence (EDD) where required
• Effective ongoing monitoring of customer activity
• Clear MLRO or AML lead oversight and escalation routes
• Regular, documented AML training
• Periodic review and independent challenge of AML arrangements

Crucially, firms must be able to evidence how controls are applied in practice, not simply that policies exist.

The AML Practice offers comprehensive support to Bureau de Change firms, meeting all their AML compliance needs, including: 

AML Audits

We perform structured AML audits designed specifically for bureau de change activity, aligned to HMRC’s supervisory approach and the ADIT framework (Adequacy, Design, Implementation and Testing). Our audits assess both the design and operational effectiveness of your AML controls.

Our audits focus on whether:

• Controls are appropriate and proportionate to your risk profile
• Customer due diligence and enhanced due diligence are applied consistently in practice
• AML decisions, reviews and escalation are clearly documented and evidenced
• Controls are periodically tested and reviewed
   

Audit outputs are clear, practical and suitable for internal governance, remediation planning and HMRC supervisory engagement.

Annual AML Gap Analysis

We carry out annual AML gap analyses to assess your existing framework against current HMRC expectations.

This includes a review of:

• Risk assessments
• Policies and procedures
• Governance and oversight
• Training records
• Day-to-day AML controls

You receive a clear written report identifying regulatory risks, gaps and practical remediation actions.

HMRC AML Registration Support

We support bureau de change businesses with HMRC AML registration, including:

• Initial registration guidance
• Review of eligibility and scope
• Ensuring AML documentation is aligned with registration requirements
• Preparing firms for post-registration supervisory engagement

This ensures firms enter supervision on a solid footing.

Annual AML Compliance Attestation

We support firms with an annual attestation of AML compliance, providing structured assurance that:

• AML controls remain appropriate and effective
• Risk assessments have been reviewed and updated
• Policies and procedures remain current
• Training obligations have been met

This creates a clear annual compliance record and strengthens governance oversight.

Policies, Procedures & Template Access

We develop bespoke AML policies and procedures for bureau de change businesses, tailored to your size, risk profile and operating model.

In addition, firms have access to templated AML policies and documents, which can be adapted as your business evolves — avoiding the need to start from scratch.

AML Training

We deliver practical AML training tailored to bureau de change risks, covering:

• Cash and currency exchange typologies
• CDD and EDD expectations
• Suspicious activity identification
• Escalation and SAR decision-making
• Staff responsibilities and accountability

Training is fully documented and suitable for supervisory review.

Ongoing AML Support & Retainers

For firms seeking ongoing assurance, we provide tailored AML support packages, which can include:

• On-hand ad-hoc support for AML queries
• Assistance with higher-risk customers and transactions
• Periodic reviews of AML documentation
• Monthly AML newsletters highlighting regulatory developments and emerging risks
• Ongoing support aligned to your business model and risk profile

Support can be scoped flexibly to include any or all of the above.