ECSH83525 - Suspension and cancellation - introduction
Source: gov.uk (2025-12-01)


Regulation 60 (https://www.legislation.gov.uk/uksi/2017/692/regulation/60) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) permits HMRC to suspend or cancel a business’s registration. The evidence required to suspend or cancel a business is the same. However, as cancellation leads to the permanent removal of the business from the register, in practice, the courts would apply a higher standard of evidence for cancellation.

Where the decision maker (DM) has reached the conclusion that suspension or cancellation of registration is an appropriate sanction, they must issue a notice of that decision. The suspension or cancellation of registration can take effect immediately or on a given date.

Suspension or cancellation of registration can be used as a stand-alone sanction or as part of a range of sanctions, depending on the facts of the case.

Suspension of registration

Suspending a business’s registration means the temporary removal of the business from HMRC’s register of supervised businesses. This effectively means that the business cannot lawfully engage in the activity, or activities they are supervised for, under MLR 2017, whilst they are suspended. Suspension is therefore a significant (albeit temporary) sanction and should only be applied for the length of time necessary to satisfy the DM that the business has satisfactorily addressed the money laundering/terrorist financing/proliferation financing risks/non-compliance.

It may be appropriate either to extend a period of suspension, or to follow it with cancellation in cases where the DM determines that the risks of money laundering or terrorist/proliferation financing and associated compliance failures have not been sufficiently addressed.

During the period of suspension, the ongoing intervention may reveal further or more significant breaches of the regulations and/or risks which could lead to the registration of the business being cancelled.

For more information on suspension of registration, see ECSH83825 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh83825).

Cancellation of registration

Cancelling a business’s registration, which is also known as a statutory cancellation, prevents the business from trading in a ‘relevant activity’ as defined in MLR 2017. Cancellation of registration ensures the permanent removal of the business from HMRC’s register of supervised businesses.

Cancellation of registration is considered a severe sanction as it prevents the business from legally trading in a relevant activity. It is therefore only to be used in the most serious cases and/or sustained non-compliance and where allowing the business to remain on the register presents too great a risk.

Additionally, registration of a business can be cancelled where, following a series of reminders:
- A business fails to pay its annual fees, the registration will be automatically cancelled (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh48075).
- A business registered under the 2007 regulations that failed to provide the additional information required for inclusion in MLR 2017 registers (regulation 54 (https://www.legislation.gov.uk/uksi/2017/692/regulation/54) or regulation 55 (https://www.legislation.gov.uk/uksi/2017/692/regulation/55) MLR 2017).
Cancellation of registration is unlikely to be appropriate where the DM considers other sanctions are more appropriate to encourage regulatory compliance and to ‘drive through’ behavioural change.

Suspension or cancellation of registration is subject to a sanctions administration charge (SAC). (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh81080)

Administrative or procedural failures

Where the cancellation is as a result of administrative failures and a low level of intervention by officers, such as-
- Failure to pay fees (but not fees due at the annual refresh of registration).
- Failure to update registration details.
The SAC is limited to £350.

Non-compliance

However, if the cancellation is as a result of -
- A compliance intervention.
- Having a BOOM in place who has a relevant unspent Schedule 3 sentence or would not otherwise meet the fit and proper test, as appropriate.
- Where the decision has involved intervention, multiple contact or more complex work.
The SAC is charged at the maximum of £2,000.

Cancellation following a suspension

If following a suspension, further grounds and evidence are used to cancel the registration, a further SAC can be applied.

If a SAC was already applied on a suspension and no further grounds or evidence are added to the cancellation, no additional SAC is applied.