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Money Laundering Regulations – Campaign for Virtual Assistants

So last week we asked you to tell us about your experience of asking HMRC for Anti-Money Laundering Regulations advice as a virtual assistant – we had a great response and Joanne Sparkes of VA Pro Magazine co-ordinated the replies (all 31 of them!) into a letter asking HMRC to clarify their position on what constitutes the need to register.

The majority seem to say that whilst what they were doing wasn’t specifically covered by official guidance they were urged to register anyway.  A number of VAs were given different advice on whether creating invoices constituted “bookkeeping services” so we have some VAs who have registered and some who haven’t.

Many thanks to Jo for co-ordinating this enquiry on behalf of the industry!

HM Revenue and Customs – Anti Money Laundering Supervision
Alexander House
21 Victoria Avenue
SS99 1AG

13 September 2017

Dear Sir or Madam,
I am writing to you to ask for help with clarification on the requirements for registration under the Money Laundering Regulations for contractors that do not see themselves as, and are not qualified as, professional bookkeeping services.
I manage a community magazine and online forum for over 800 Virtual Assistants in the UK. Some of them offer bookkeeping as part of their services, producing accounts and reports, and the requirement to register under MLR for them is quite clear.
However, many Virtual Assistants are providing administrative assistance and secretarial services to their clients, as freelancers, and there are some tasks that they undertake, not always done by a bookkeeper to a business, but that do involve financial data such as:

  • raising and sending invoices on behalf of a client (either word processed, or increasingly directly in a modern, online accounts package such as Xero)
  • chasing outstanding invoices
  • data entry; transferring amounts from paper receipts in to an electronic form on a spreadsheet or an online accounts package in preparation for review by a bookkeeper and/or accountant
  • forwarding invoices and receipts to Receiptbank or an equivalent service
  • paying invoices through a client’s online banking service
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These tasks in a larger company might be done in house daily by an admin assistant, with an external bookkeeper or accountant involved less often. In smaller and growing companies subcontracted assistants are increasingly performing this administrative role on a daily basis.
Confusion arises around what constitutes the “recording” of financial data. In our forum we have had many discussions around the need to register and I normally suggest that anyone involved with financial records should, and quote the definition of an accountancy service provider, and that they should get in touch with HMRC for individual advice.
However, I have recently surveyed our community and received very conflicting reports. Some VAs look at the advice given on your website and see that they are not a professional bookkeeping service and decide not to register.
Some have called, or written to, the HMRC helpline and there are broadly three equal sets of conflicting responses.

  • Some VAs doing the admin tasks described above are being told they do need to register with a few being issued with fines for not registering soon enough
  • Some are being told they don’t need to register when they are carrying out similar work.
  • Others are having the website definition quoted back to them and told to decide for themselves, with many ending up registering “just in case”.
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This is causing great confusion in our industry and continued uncertainty and anxiety about what’s actually needed.
Would it be possible to please provide me with a statement as to when a data entry task, when always further supervised by a qualified and registered bookkeeper or accountant, becomes a recording task that requires individual registration under the money laundering regulations?
If all administrative tasks involving the writing down of financial numbers require registration, would you please consider updating the information on your website here
to include office administration services in addition to professional bookkeeping services.
This would allow me to confidently give information to our group and help us all, but especially those that have not considered that they should register, comply with the regulations fully.
Yours faithfully,
Mrs. Joanne Sparkes

So we look forward to receiving a response and will let you know…


A while back Jo Sparkes of VA Pro Mag worked very hard to get a definitive answer from HMRC regarding virtual assistants and the Anti Money Laundering Regulations.

We found that some VAs had been told they didn’t need to register, whilst others had been told they did – despite doing the same task for clients.  HMRC’s guidance on their website is not 100% clear and Jo chased them (relentlessly!) for an answer – which we now have:

  1. Anyone advertising or doing Bookkeeping or Accountancy should be registered.
  2. If you are just transferring data to a spreadsheet or document and are not analysing the information then you are NOT REQUIRED to register under the Money Laundering Regulations.
  3. If you are creating the spreadsheets and adding the financial information on behalf of the client you are in scope and REQUIRED TO REGISTER under the Money Laundering Regulations
  4. Raising sales invoices on clients software e.g xero, sage – This would come under bookkeeping and you would be REQUIRED TO REGISTER
  5. Entering purchase invoices onto clients’ software e.g xero, sage. – Again this would come under bookkeeping and you would be REQUIRED TO REGISTER
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I.E. If you are in any way responsible for the figures showing on the financial records of a company then you will need to be registered under the Money Laundering Regulations.

Hope that clarifies the situation!  Many thanks to Jo Sparkes of VAProMag for sharing.

UPDATE FROM HMRC MEETING: https://www.vapromag.co.uk/money-laundering-regulations-for-virtual-assistants/


  1. Anousha on 7 October, 2017 at 1:45 pm

    I look forward to that reply. Let’s hope it’s clarified and, sooner rather than later.

  2. Roxana on 2 January, 2018 at 7:03 pm

    Has there been a response from HMRC?

  3. Laura Fellows on 28 February, 2018 at 3:30 pm

    I would also like to know whether there has been a response to this. I am about to set up as a VA and don’t know whether I can offer this service, as I cannot afford the initial HMRC costs.

    • Caroline on 28 February, 2018 at 3:55 pm

      Hi guys – we sent out an update to members via email on 16 feb – do make sure you’ve joined as a member so you get updates!! I’ll post the response here too though.

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