ECSH51225 - Money service business supervision
Source: gov.uk (2025-04-16)


Every relevant person (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh160000) (business or individual) that falls within the scope of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) must be registered with either HMRC or the Financial Conduct Authority (FCA). They must also be supervised by a supervisory authority for anti-money laundering purposes.

In situations where there is more than one supervisor for a relevant person, the supervisory authorities may agree between them who will act as the supervisory authority for that person.

HMRC, the FCA, the Gambling Commission (GC) and the professional body supervisors listed in schedule 1MLR 2017 are the Supervisory Authorities for relevant persons falling within the scope of MLR 2017. See ECSH30500 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh30500).

MSBs are required to register with HMRC for supervision unless they are already supervised by the FCA. MSBs that are supervised by the FCA are credit and financial institutions (including money service businesses) which are authorised persons under The Financial Services and Markets Act 2000 (FSMA) and include E-Money institutions. The GC supervises casinos that carry out MSB activities, though these businesses must also be registered with HMRC for supervision. This is done through an arrangement with the GC providing details to HMRC. The businesses do not pay HMRC fees and are not inspected by us.MSBs that are supervised by HMRC and carry out money transmission will also need to be registered or authorised with the FCA under the Payment Services Regulations 2017 (PSR).

If a firm is authorised by the FCA under the Financial Services and Markets Act 2000 (FSMA), and provides currency exchange, money transmission or cheque cashing services, and falls within scope of MLR 2017 as an MSB, then they will be supervised under MLR 2017 by the FCA for all their activities under the MLR 2017 (see ECSH42000 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh42000)). Money transmitters (MSBs) that solely provide payment services as a small payment intuition (SPI) or an authorised payment institution (API) - see here (https://www.handbook.fca.org.uk/handbook/PERG/15/4.html) - will be supervised by HMRC under MLR 2017 and registered with the FCA to provide payment services under the PSR.

The contractual and business agreements between businesses will affect how they are registered with HMRC and the FCA respectively. At a premises there may be a MSB registered as a principal and also registered separately as an agent of another principal. The MSB sector does not have any professional body supervisors. The FCA register (https://register.fca.org.uk/s/) can be used to check if a business is registered with the FCA. The GC public register (https://www.gamblingcommission.gov.uk/public-and-players/public-register) can be used to view details of licensed businesses, individuals, regulatory actions and premises. The GC is not a registering authority under MLR 2017, and any MSB that it supervises must register with either HMRC or the FCA.

Whilst businesses conducting MSB activities such as currency exchange and cheque cashing may meet the regulation 15 MLR 2017 exemption criteria (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh43500) (by engaging in financial activity on a limited or occasional basis), regulation 15 MLR 2017 makes it clear that for this exemption to apply, the activity must not be the transmission or remittance of money by any means. Money transmission or remittance is not excluded from registration, irrespective of whether it is carried out on an occasional or very limited basis and all other conditions set out in regulation 15(3) MLR 2017 are met.