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Anti Money Laundering Regulations for Virtual Assistants

If you offer bookkeeping or accountancy services, you should be registered for Anti Money Laundering Regulations.  Over the course of the last 18 months or so we've been working closely with VAProMag and HMRC to achieve two aims for the VA industry:

  1. Clarity surrounding who needs to register - including consistent advice when people call up or email
  2. A concession for VAs who do small tasks as part of their overall work for clients - it's unfair that someone who simply preps invoices on an online accountancy programme and gets a couple of hours work a month doing that has to pay the same registration fee as a firm of accountants who do 40 hours a week!

We are thrilled to announce the updated policy:


The relevant part being:

Virtual assistants that do not need to register

If you only provide a small amount of accountancy services as a virtual assistant you may not need to register.

You will not need to register if all of the following applies:

  • virtual assistant is your main business
  • your annual business turnover is not more than £30,000
  • no more than 5% of your total business turnover applies to accountancy service activities
  • the accountancy services you provide support your main business
  • there is no other business activity you need to register under Money Laundering Regulations
  • your work is reviewed by an accountant or bookkeeper who is registered for money laundering supervision

If you have worked out that you do not need to register, you should send an email to: [email protected] providing:

  • a declaration of how your business meets each of the criteria
  • details of your business, including a contact:
    • name
    • address
    • email address
    • telephone number

Once you’ve sent the email to us, there’s nothing more you need to do except keep a copy for your business records.

If the business changes in the future, and any of the criteria do not apply, you must apply to register for supervision by HMRC or one of the professional body supervisors of accountancy service providers.

HMRC may contact or visit virtual assistants claiming the concession to check that the qualifying conditions are being met.

(Source: HMRC)

HMRC have also asked us to flag two important things:

  • Make sure you remain alert to any change in business circumstances that mean they would no longer be eligible. Should that ever become the case, then they would need to apply for registration in the normal way. (i.e. if your turnover increases or if you end up doing more than the 5% allowance)
  • Keep a copy of the email you send to HMRC as proof that you claimed the concession.

UPDATE: April 2021 - AMLR team changes its name to Economic Crime Supervision (ECS) https://www.societyofvirtualassistants.co.uk/2021/04/09/economiccrimesupervision-mlr/

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  1. Anuta on 19 January, 2020 at 7:18 pm

    This has really cleared this for me. Thank you!

  2. Emma Baker on 27 July, 2020 at 2:46 pm

    Thank you; same as Anuta- this has clarified things for me.

  3. Elizabeth Brierton on 5 May, 2023 at 3:06 pm


    Has anyone tried to claim exemption recently (ie in the last year). Based on the example given in this article, prepares invoices in an online system – how have you addressed the last criteria about supervision please?

    Thank you!

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