{"id":10997,"date":"2026-04-23T09:59:06","date_gmt":"2026-04-23T09:59:06","guid":{"rendered":"https:\/\/www.amlcc.com\/?p=10997"},"modified":"2026-04-20T09:59:44","modified_gmt":"2026-04-20T09:59:44","slug":"what-happens-during-an-hmrc-aml-inspection","status":"publish","type":"post","link":"https:\/\/www.amlcc.com\/bm\/what-happens-during-an-hmrc-aml-inspection\/","title":{"rendered":"What happens during an HMRC AML inspection?"},"content":{"rendered":"\n

What happens during an HMRC AML inspection?<\/h1>\n\n\n
\"Richard<\/div>
Richard Simms<\/span>

Director and Founder of AMLCC and AMLCC Consult<\/h3><\/div><\/div><\/div><\/div>\n\n\n
\"What<\/figure><\/div><\/div>\n\n\n\n
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An HMRC AML inspection is a compliance check carried out under the UK\u2019s Money Laundering Regulations 2017<\/a> (as amended) (MLRs) to assess whether your business is meeting its legal obligations. <\/p>\n\n\n\n

HMRC supervises estate agents, letting agents, high-value dealers, art market participants and accountancy service providers not supervised by a professional body. If your business falls into one of those categories and is registered with HMRC for AML supervision, expect that you will have (and need to be prepared for) an inspection.<\/p>\n\n\n\n

The purpose of an inspection is not to catch you out. As HMRC sets out in its published guidance<\/a>, officers are there to check that your controls are working, help you understand your obligations and identify any areas that need attention. <\/p>\n\n\n\n

How HMRC selects businesses for inspection<\/strong><\/strong><\/strong><\/strong><\/strong><\/strong><\/h2>\n\n\n\n

HMRC takes a risk-based approach to supervision, which means inspections are not random. Resources are allocated based on an assessment of where money laundering<\/a> risk is highest across the sectors HMRC supervises. <\/p>\n\n\n\n

Your business may be selected for inspection because information suggests there is a risk of money laundering exposure, because your registration is due for review or as part of a planned programme for your sector.<\/p>\n\n\n\n

HMRC also conducts unannounced visits, though the more usual route is contact by phone to arrange a convenient time, followed by a written confirmation of the date, who the officer will want to speak to and what records they will want to see. An inspection visit does not, in itself, mean HMRC thinks something is wrong.<\/p>\n\n\n\n

Visit or office-based check: understanding the difference<\/strong><\/strong><\/h2>\n\n\n\n

HMRC has two main routes for compliance checks. The first is a physical visit to your business premises. The officer will normally attend your main site so they can see your systems and records in context, speak to the right people and test whether your controls work in practice.<\/p>\n\n\n\n

The second route is an office-based check, conducted by phone or desk review. The purpose and scope are the same as a visit. HMRC will request the same information and documentation and will carry out equivalent checks. In many straightforward cases, an office-based check is sufficient. A visit may follow if the business is complex or if concerns arise that need further investigation.<\/p>\n\n\n\n

Both formats require your MLRO \/ nominated officer or the person responsible for AML compliance to be available and ready to answer questions about how your policies and procedures operate in practice.<\/p>\n\n\n\n

Who needs to be present<\/strong><\/strong><\/strong><\/strong><\/strong><\/h2>\n\n\n\n

HMRC will want to speak to the owner of the business or, where the business has a management structure, the senior person responsible for AML compliance, at the start of the visit. <\/p>\n\n\n\n

After that initial conversation, you need to make sure that a responsible person is present who can answer questions and provide documents. Your MLRO \/ nominated officer or the senior manager responsible for AML compliance should be there for the duration of the visit.<\/p>\n\n\n\n

The officer may also want to speak to other members of staff to test whether they understand your AML policies, controls and procedures and know what to do if a concern arises. A firm where the compliance knowledge sits entirely with one person, and front-line staff cannot articulate the basics, is a firm with a training gap that will be noted.<\/p>\n\n\n\n

You can have a professional adviser present but they cannot answer questions on your behalf. Only you can explain how your business actually operates.<\/p>\n\n\n\n

What HMRC will examine<\/strong><\/strong><\/h2>\n\n\n\n

The inspection centres on your AML framework. HMRC will always check the following:<\/p>\n\n\n\n