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HMRC expects your risk assessment and your written policies to exist when you
apply. It can require the risk assessment as part of your application
(regulation 57(2)(f)), and its own guidance says it may reject or refuse an application
if you don't have these in place.
£295 — AML Documents Pack. Four documents, written for your business
from your answers and delivered within one working day of payment: a gap analysis of
where you actually stand, your practice-wide risk assessment under regulations 18 and
18A, your written policies, controls and procedures under regulations 19 and 19A, and a
compliance calendar carrying your own dates. You review, correct and adopt them. £495 — Done-with-you. The same pack, plus a call to work through the
gap analysis with you, fill in properly what we've had to flag as missing, and settle
the open questions before you adopt anything.
No VAT — we're not VAT-registered. Launch pricing, confirmed in writing before any
invoice issues · full terms.
Led by a chartered accountant, qualified twenty
years, across UK audit, practice and government finance.
The 21 days, said accurately
You'll see it written elsewhere that you have 21 days from applying to HMRC. That isn't
what the Regulations say. Under regulation 57(3), HMRC may require you to
provide further information within 21 days beginning with the date the
requirement is issued — the clock starts when HMRC asks, not when you apply.
Miss it and regulation 59(1)(a) says HMRC may refuse to register you.
Which is the real point: the 21 days is only a problem if the documents don't exist
yet. HMRC must give you its decision within 45 days of your application, or of receiving
what it asked for (regulation 59(2)). And you can trade as soon as you've applied —
regulation 56(5) — though trading as an estate agency business without being registered
at all is a criminal offence.