N Bevan v HMRC

Cathya Djanogly

In N Bevan v HMRC [2016] UKFTT 674 (7 October 2016) the FTT found that a small firm of accountants which had not complied with the Money Laundering Regulations SI 2007/2157 was liable to a penalty.

The Regulations implement the UK’s obligations under Directive 2005/10/EC which relates to the prevention of the use of the financial system for the purpose of money laundering and terrorist financing. HMRC is the supervisory authority for auditors external accountants and tax advisers which are not supervised by any other specified body. Under the Regulations a person to whom the Regulations apply must apply ‘customer due diligence’ conduct ‘ongoing monitoring’ of its business relationships and apply ‘enhanced ongoing monitoring’ on a ‘risk sensitive basis’.

N Bevan operated a small accountancy business with about 75 clients. It provided end of year accounts preparation and assistance with self-assessment corporation...

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