Licence Applications

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For many businesses, obtaining the correct anti-money laundering supervision is a legal requirement before they can trade, whether through HMRC or as an FCA Annex 1 firm. The application process is far more than an online formality. Supervisors expect firms to understand their money laundering and terrorist financing risks, have appropriate controls in place, and be able to evidence how those controls will operate in practice.

At The AML Practice, we support HMRC-supervised businesses and FCA Annex 1 firms with AML licence and registration applications. We help firms prepare the documentation, governance arrangements and risk-based controls needed to make applications credible, robust and regulator-ready.

The objective is not simply to submit an application, but to present a clear and defensible explanation of the business model, customer base, products, jurisdictions and financial crime controls. A weak application can lead to delay, challenge or refusal. A well-prepared application gives the supervisor confidence that the business understands its obligations and is ready to operate responsibly.

We support firms that require AML supervision from HMRC or the FCA, including:

• Accountancy and bookkeeping firms 
• Trust and company service providers 
• Money remittance firms 
• Bureau de change providers 
• FCA-supervised Annex 1 firms 
• Legal services firms

This service is suitable for new businesses applying for AML supervision for the first time, existing firms adding a new supervised activity, overseas businesses establishing a UK presence, or firms that have attempted an application and received questions or challenge from the supervisor.

HMRC supervises a wide range of businesses for anti-money laundering purposes. These include money service businesses, accountancy service providers and trust and company service providers.

For HMRC-supervised firms, the application must be supported by a clear understanding of the firm’s risk profile and control framework. The supervisor may ask about the firm’s ownership, management, responsible persons, customer types, services, delivery methods, jurisdictions, source of funds controls, staff training and suspicious activity reporting arrangements.

We help firms prepare the application and supporting AML framework so that the business can demonstrate that it is not only applying for registration, but is ready to meet its obligations under the Money Laundering Regulations.

Some firms are not otherwise authorised by the FCA for mainstream regulated financial services, but still fall within the FCA’s AML supervisory perimeter because they carry on Annex 1 financial institution activities. These may include certain lending, financial leasing, payment-related, financial guarantee, money broking, portfolio-type, investment-related or other financial activities within the scope of the Money Laundering Regulations.

For these firms, the key issue is often not simply completing the application form. The firm must be able to explain why it falls within the Annex 1 perimeter, what activities it carries on, who its customers are, how money flows through the business, and what financial crime risks arise from the activity.

We support firms by assessing the relevant activity, preparing the AML application, drafting or reviewing the required AML documentation, and helping the firm respond to any questions raised by the supervisor.

Our support can include:

• Initial assessment of whether AML supervision is required 
• Identifying whether HMRC or the FCA is the relevant AML supervisor 
• Reviewing the business model and financial crime risk profile 
• Preparing the AML registration or licence application 
• Drafting or refreshing the firm-wide risk assessment 
• Preparing AML policies and procedures 
• Designing customer due diligence and enhanced due diligence controls 
• Preparing governance and senior management responsibility records 
• Developing suspicious activity reporting procedures 
• Preparing staff AML training materials 
• Responding to supervisor questions and information requests 
• Supporting firms where an application has stalled or been challenged 

A strong AML application is supported by clear, tailored documentation. The supervisor will expect the firm’s documents to reflect what the business actually does, not generic wording copied from another business.

We prepare and review documents including:

• Firm-wide risk assessment 
• AML policy and procedures 
• Customer due diligence procedures 
• Enhanced due diligence procedures 
• Sanctions screening procedures 
• Suspicious activity reporting process 
• Staff training plan 
• Governance and responsibility framework 
• Compliance monitoring plan 
• Record-keeping procedures 

These documents should show how the firm identifies, assesses, manages and monitors financial crime risk in a way that is proportionate to its business.

Not every application proceeds smoothly. The supervisor may ask further questions, request additional evidence, challenge the firm’s risk assessment, question the suitability of responsible persons, or ask for more detail on customer onboarding, source of funds, high-risk jurisdictions, sanctions screening or ongoing monitoring.

We help firms respond clearly and professionally. This includes reviewing the supervisor’s questions, identifying the underlying concern, preparing evidence-based responses, and updating the firm’s AML documentation where required.

The aim is to avoid defensive or unclear responses. Where a weakness exists, it should be addressed properly. Where the firm’s position is reasonable, it should be explained clearly and supported by evidence.

AML licence applications sit at the intersection of regulation, financial crime risk, governance and commercial reality. A firm must satisfy the supervisor, but the controls also need to work in the real business.

The AML Practice helps firms prepare applications that are practical, risk-based and defensible. We understand that most applicants are not trying to build unnecessarily complicated compliance frameworks. They need proportionate controls, clear documentation and a credible explanation of how the business will meet its obligations.

Our focus is simple: helping firms obtain the correct AML supervision and build a framework that can withstand scrutiny after approval.

If you are applying for AML supervision with HMRC or the FCA as an Annex 1 firm, or if you are unsure whether your business requires AML registration, The AML Practice can help you assess the position and prepare a clear, defensible application.