HMRC have updated their guidance The fit and proper test.
“Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) regulations 2017 (the regulations), money service businesses (MSBs) and Trust or Company Service Providers (TCSPs) are subject to the fit and proper test.
The test is to make sure that the applicant, and its beneficial owners, officers and managers (BOOMs) are suitable people to undertake those roles. BOOMs must pass the test before HMRC will register the business.
Whilst a person’s skills and experience to act in a given role is considered as part of the test, the fit and proper test does not test whether your business is professionally run or operated.
Accountancy service providers, art market participants, estate agency businesses, high value dealers and letting agency businesses are subject to approval checks and should follow guidance on HMRC approval checks.”
The guidance has been updated because beneficial owners, officers and managers will now be notified via their Government Gateway account if they fail the fit and proper test or are not approved and HMRC will not register the business. The guidance on approval checks has been moved to a new page titled HMRC approval checks.