Handy tips and guidance for completing your submission
Here are our top tips to help you complete this year’s renewal:
1. You can access your renewal either through the link in the email, or by logging into your member account here https://pilot-portal.tax.org.uk/Secure-area/Members-Area/Compliance. If these links do not work for you then further details of how to access the 2023/24 renewal form once you are in the portal are available here.
2. The form works best if accessed through the following browsers:
- Microsoft Edge v86 or higher
- Google Chrome v86 or higher
Members have reported problems when using Firefox and Internet Explorer so these browsers are best avoided.
3. Your AML renewal form and fee payment must be completed by midnight on 31 May 2023. You will be directed to pay online immediately after you have submitted the form. If your fee payment is outstanding after 31 May, you will have failed to renew your AML supervision on time (see point 4 for consequences).
4. It is a legal obligation under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, to be supervised for AML. If you fail to renew on time, you will be referred to the Taxation Disciplinary Board for a fine or other disciplinary action.
5. The cost of annual supervision for 2023/24 is £330. The AML supervision year covered is from 1 June 2023 to 31 May 2024.
6. There are some new questions included this year including one on how clients pay your fees and one on particular types of higher risk clients which you might act for. Have details to hand in relation to your clients, how they pay their fees and the types of services you provide before you begin completing the form.
7. Last year we took out any questions regarding whether or not you have undertaken any Trust or Company Service Provider work (TCSP) but owing to continuing government focus on this area of work we have added a question back in this year. We recommend that you review the guidance (see below links) on what constitutes TCSP work before you begin completing the form to be able to answer this question:
See ATT https://www.att.org.uk/members/anti-money-laundering section on ‘HMRC TCSP register Q&A for businesses’ for further information on these services.
8. At Q.33, you are asked “Do your AML policies and procedures ensure you undertake all sanctions related checks necessary as part of your client due diligence procedures to ensure you are allowed to act for a client?” This continues to be important given the ongoing Russian sanctions in place following Russia’s invasion of Ukraine. Further information can be found on our websites:
9. For sole practitioners, on questions that relate to “all staff and principals”, you should include yourself as a principal in your response (except for Q.37 which relates to communicating policies and procedures to staff where you can put ‘N/A’).
10. When putting the number of Beneficial Owners, Officers and Managers (BOOMs) on your form at Q.49, please remember to include yourself.
11. Relating to Q.50 you do not need to repeat criminality checks for existing BOOMs but you do need to carry out criminality checks for any additional BOOMs appointed on or after 1 June 2022 (if you have not done this already) and email the results to us separately at [email protected].
12. There is a function at the end for you to review your answers and if necessary, edit any errors before you submit the form. This is particularly helpful when completing the form on a mobile phone, as experience has shown that it is easy to hit the wrong button and give an erroneous non-compliant answer.