ECSH48581 - Cancellation and suspension of registration: operational guidance: suspension process
Source: gov.uk (2025-03-09)


You should consider the money laundering, terrorist financing or proliferation financing (MLTFPF) risks that a business poses to determine that a suspension is the appropriate sanction. See the guidance on determining an appropriate sanction in ECSH81075 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh81075).

Some examples of situations where you may determine that a suspension is the most appropriate sanction when a business has not complied with The Money laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) are:
- Failure to provide documents required under regulation 66 MLR 2017 after a type 4 penalty has been imposed.
- Failure to add a beneficial owner, officer or manager (BOOM) to its registration after a type 3 penalty has been imposed on the business for failure to notify HMRC of a change.
- Failing to maintain an adequate written risk assessment and/or policies, controls, and procedures.
- Failure to pay a penalty.
- The appointment of a BOOM who has failed the approvals test.
- The appointment of a BOOM who has failed the fit and proper test.
Suspending a business’ registration is a temporary measure so you must have a clear plan as to what actions the business must take to have its registration re-instated.

You will also have to consider the MLTFPF risk presented by the business when determining if you should:
- Issue an intention to suspend letter which will give the business the opportunity to rectify the issue without ceasing relevant activity:
- Issue an intention to suspend letter which will take effect at a future date; or,
- If the interest of the public requires an immediate suspension in line with regulation 60(10) MLR 2017 (https://www.legislation.gov.uk/uksi/2017/692/regulation/60), you may decide to proceed straight to issuing a notice to suspend with immediate effect.
Intention to suspend

You will draft an intention to suspend letter to the business. If the suspension is in scope of the terms of reference for Governance Panel (GP) you will need to submit it to GP before issuing the letter. The letter must give the business an appropriate amount of time to make representations about the suspension. Your next action will depend on the following outcomes:
- The business meets the requirements of the intention to suspend letter prior to the suspension deadline.
Action: You will issue a further letter to the business confirming that a suspension is no longer necessary. The business can continue to provide relevant activity.
- The business provides representations about the suspension.
Action: You will consider all the points raised in the representations and based on the information, decide if you will proceed with the suspension or not.
- The business does not satisfy the requirements of the intention to suspend letter.
Action: You will proceed to issue a notice to suspend.

Notice to suspend

You will draft a notice to suspend to the business. If the suspension notice is within scope of the terms of reference for Governance Panel (GP) you will submit the case to GP before issuing the notice to the business. If you are issuing a notice to suspend because the business has not satisfied the requirements of your intention to suspend letter, your notice should be ready to be issued on the date specified in your intention to suspend letter.

Once you issue the notice to suspend to the business it is not allowed to engage in relevant activity for the defined period of time or until the issues identified in the notice are rectified and you have notified the business that the suspension has been lifted. Your next action will depend on the following outcomes:
- The business meets the requirements for the suspension to be lifted.
Action: You will issue a letter to the business confirming that the suspension has been lifted and that it can resume relevant activity
- The business does not satisfy the requirements for the suspension to be lifted within the timeframe specified in the notice. You are satisfied that the business is working towards addressing the risks identified in the notice
Action: You can consider imposing a further suspension which will come into effect on the day your initial suspension is due to be lifted to give the business time to comply with the terms of the notice. This is considered to be a new sanction and will require submission to the GP if appropriate.
- The business does not satisfy the requirements for the suspension to be lifted within the timeframe specified in the notice. You are satisfied that the business has failed to take the necessary action to address the risks identified in the notice
Action: You should consider imposing further sanctions on the business e.g. cancellation. Any further sanctions will require submission to the GP, where they are within scope of the terms of reference, before the initial suspension is due to be lifted.

Suspending an accountancy service provider

When you suspend the registration of an accountancy service provider (ASP) you should send an email

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

﻿<p class="MsoNormal">to advise the team that ASP has been suspended. The team will then remove the business’ agent codes which will prevent it acting as an agent during the suspension. Agent maintainer team are responsible for the provision and management of ASP agent codes.</p>

Suspending a money service business

If suspending the registration of a money service business (MSB), you should:
- Contact the Financial Conduct Authority (FCA) to notify them of the suspension if the business acts as a money transmitter. Further guidance on contacting the FCA when suspending the registration of a money transmitter is available in ECSH47534 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh47534).
- If the MSB acts as an agent of another MSB you should contact the business’ principal firm to advise that its agent’s registration has been suspended. Further guidance on contacting a principal firm is available in ECSH47535 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh47535).
- If the MSB has any agents, you should contact the business’ agents to advise them that they can no longer engage in relevant activity under that principal.
For further details of the suspension process, see the SWIs in the knowledge library.