Money laundering supervision sanctions and appeals

HMRC may impose measures, including a financial penalty, if you do not comply with the Money Laundering Regulations. In more serious cases, it may consider criminal prosecution.

This guide tells you what you can do if you disagree with an HMRC decision. It explains:

• when to ask for a review
• when to appeal to the tribunal
• civil penalties and criminal offences under the Money Laundering Regulations

If you disagree with an HMRC decision

Challenging an HMRC decision

You might want to challenge an HMRC decision if, for example, HMRC:

• refuses to register your business under the Money Laundering Regulations
• charges you a penalty for not complying with the Money Laundering Regulations
• publishes a statement censuring your business
• prohibits a person from managing

If you disagree with your registration being suspended or cancelled write to:

When HMRC will offer you a review

When HMRC tells you about a decision, it will usually offer you a review by an officer who was not involved in the original decision.

You cannot carry out any regulated activity while HMRC does a review if the decision was to:

• refuse to register your business
• suspend or cancel your registration

When you can appeal the decision

You can appeal to a tribunal if you disagree with the outcome of the review.

Penalties and other sanctions if you do not comply with the Money Laundering Regulations

If you fail to comply with the Money Laundering Regulations you may:

• have to pay a financial penalty to HMRC
• face other civil sanctions or a criminal prosecution

You’ll be protected from this if you can show you have followed HMRC’s Money Laundering Regulations guidance. HMRC can take various measures, from warning letters to criminal prosecution if your business does not comply with the Money Laundering Regulations.

These measures are to encourage you to comply with the Money Laundering Regulations. The action that HMRC takes depends on the seriousness and potential impact of the failures identified.

The penalty, or other action that HMRC imposes must be appropriate for the failure and at a level that:

• is proportionate to the failure
• deters non-compliance

The amount of the penalty, or other action, will take account of the:

• reason for non-compliance
• seriousness of the offence
• compliance history of the business
• relative size of the business
• benefits received
• amount exposed to money laundering activities

HMRC will allow reductions to a financial penalty when you make an unprompted disclosure that you have breached the regulations. An unprompted disclosure is when you contact HMRC before we contact you for any type of enquiry or intervention.

You should make a disclosure to HMRC by email, which should include how you intend to become fully compliant.

You can find detailed information about the penalties for failing to comply with the Money Laundering Regulations in the HMRC civil measures guidance.

HMRC may publish details of your business if you do not comply with the regulations. You can find details of businesses that have not complied with money laundering regulations.

Sanctions administration charge

HMRC introduced a penalty administration charge for all anti-money laundering supervision penalties issued from 25 July 2018.

From 1 December 2025 this charge has been extended to cover any civil sanctions issued by HMRC for failing to comply with the regulations and is referred to as the sanctions administration charge.

The charge is for costs of issuing sanctions to businesses that do not comply with the Money Laundering Regulations. This means HMRC will also charge a sanction administration charge if:

• it suspends or cancels your registration
• issues a censuring statement
• imposes a prohibition on management

Non-compliance sanctions

You’ll have to pay a £2,000 sanction administration charge as well as the financial penalty for breaches of the Money Laundering Regulations such as failures for:

• customer due diligence
• failing to register for supervision
• policies, controls and procedures
• record keeping
• risk assessment

If the penalty amount is less than £1,500, the penalty administration charge will be capped at the value of the penalty.

All other sanctions

HMRC will charge up to £350 as well as the financial penalty for failures to:

• tell HMRC of changes to your business
• provide information requested

Proceeds of Crime Act and the Terrorism Act offences

If you do not comply with the Money Laundering Regulations (which could lead to criminal prosecution), you could also be committing offences under the:

• Proceeds of Crime Act 2002
• Terrorism Act 2000

You can get more detailed information about the criminal offences and penalties for money laundering and terrorist financing on anti-money laundering for:

• an accountancy service provider
• an art market participant
• an estate agency business
• a high value dealer
• a letting agency businesses
• a money service business
• a trust or company service provider