Money Remittance Firms (FCA Authorised – HMRC AML Supervised)

Money remittance businesses are typically authorised or registered by the FCA as:

• Authorised Payment Institutions (APIs)
• Small Payment Institutions (SPIs)
   

However, under the Money Laundering Regulations 2017 (MLRs), AML supervision for many remittance firms is conducted by HMRC rather than the FCA.

This means:

• HMRC is your AML supervisory authority
• HMRC conducts compliance inspections
• HMRC can impose civil penalties for AML failures
   

Even though the FCA authorises your payment services activity, your AML programme must meet HMRC supervisory expectations. Understanding this distinction is critical.

HMRC expects money remittance firms to operate a fully compliant AML framework aligned with the Money Laundering Regulations 2017 and current UK guidance.

This includes:

1. A Documented Firm-Wide Risk Assessment
You must assess and document your exposure to money laundering and terrorist financing risks, including:

• Cross-border transactions
• High-risk jurisdictions
• Agent networks
• Cash-intensive activity
   

2. Robust Customer Due Diligence (CDD)

• Identity verification procedures
• Enhanced Due Diligence (EDD) for high-risk customers
• Ongoing monitoring of transactions
   

3. Effective Transaction Monitoring
Remittance firms are inherently higher-risk due to rapid funds movement and international exposure. Monitoring must be proportionate, documented and demonstrably effective.

4. Policies, Controls and Procedures
Your AML policies must reflect your actual operating model — not generic templates.

5. SAR Reporting and Record Keeping
You must have clear escalation processes and maintain appropriate AML records for inspection.

HMRC inspections are increasingly data-driven and risk-based. Firms that rely on outdated templates or weak documentation are vulnerable to enforcement action.

 The AML Practice offers comprehensive support to Money Remittance firms, meeting all their AML compliance needs, including:

AML Audits

We perform structured AML audits designed specifically for money remittance 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, with particular focus on cross-border payment risk and transaction velocity.

Our audits examine whether:

• Controls are appropriate and proportionate to your cross-border risk exposure
• Customer due diligence and enhanced due diligence are applied consistently across channels
• Agent and intermediary oversight is documented and risk-based
• Transaction monitoring thresholds are calibrated to remittance risk
• AML decisions, reviews and escalation processes are clearly documented
• Controls are periodically tested and independently reviewed
   

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

Annual AML Gap Analysis

We carry out annual AML gap analyses to assess your framework against current HMRC expectations under the Money Laundering Regulations 2017.

This includes structured review of:

• Firm-wide risk assessments
• Cross-border and jurisdictional risk analysis
• Agent oversight arrangements
• Policies and procedures
• Governance and MLRO oversight
• Training records
• Transaction monitoring effectiveness
   

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

HMRC AML Registration & Supervision Support

We support money remittance businesses with HMRC AML registration and supervisory readiness, including:

• Initial AML registration guidance
• Review of business scope and regulated activities
• Alignment of AML documentation with registration declarations
• Preparation for HMRC inspection or information requests
   

This ensures firms enter and remain within supervision on a strong and defensible footing.

Annual AML Compliance Attestation

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

• AML controls remain appropriate and proportionate
• Risk assessments have been reviewed and updated
• Cross-border risks have been reassessed
• Policies and procedures remain current
• Training obligations have been fulfilled
   

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

Policies, Procedures & Template Access

We develop bespoke AML policies and procedures tailored specifically to money remittance operating models, including:

• Cross-border risk controls
• Transaction monitoring frameworks
• Agent oversight procedures
• Escalation and SAR governance
   

Firms also receive access to structured AML templates and documentation frameworks, which can be adapted as your business grows.

AML Training

We deliver practical AML training tailored to money remittance risk, covering:

• Remittance and cross-border typologies
• High-risk jurisdiction exposure
• Agent network risks
• CDD and EDD expectations
• Suspicious activity identification
• Escalation and SAR decision-making
• Senior management oversight responsibilities
   

Training is fully documented and suitable for HMRC supervisory review.

Ongoing AML Support & Retainers

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

• On-demand AML advisory support
• Assistance with higher-risk customers or transactions
• Review of complex cross-border payment scenarios
• Periodic AML documentation updates
• Regulatory update briefings and newsletters
• Board and MLRO advisory support
   

Support can be scoped flexibly to include any or all of the above, aligned to your risk profile and growth plans.