Patrick Boyers and Jack Murphy in JMW’s Regulatory Team have made successful representations to Her Majesty’s Revenue and Customs (“HMRC”), resulting in no further action being taken.

Background

 JMW represented an accountant who was alleged to have undertaken relevant, regulated accountancy work without having the appropriate supervision in place to monitor and comply with anti-money laundering (“AML”) rules and regulations. HMRC had written to the accountant and asked them to offer an explanation for the gap in their registration with the HMRC supervision scheme and requested further information about the revenue drawn from any unsupervised relevant conduct. The accountant was at risk of receiving a financial penalty for unsupervised accountancy work and possible publication on the HMRC’s register of fines, including reputational damage for unsupervised accountancy work.

How did JMW help?

 After securing an extension to the original representations deadline, JMW made written representations on behalf of the client about the circumstances of the accountancy work undertaken and the gap in the client’s registration with the HMRC AML supervision scheme. Those representations also outlined the circumstances of any revenue that may have been obtained as a consequence of unsupervised regulated activity. These were submitted to HMRC with a view to persuading them that action in this case was disproportionate and unnecessary.

What was the Outcome?

HMRC responded to the representations submitted by JMW and confirmed that having considered them in full, they would be taking no further action in respect of the client and would not be looking to impose any form of financial or other penalty for the alleged unsupervised relevant conduct.

Patrick Boyers said: “This represents a fair and pragmatic outcome in the circumstances and we are grateful to HMRC for being so receptive to the representations sent on our client’s behalf.”