By Simon Harbord, Senior Associate, Teal Compliance
If you’ve been enjoying the calm of summer, brace yourself, because HMRC has decided to drop a little something into our inboxes. And no, it’s not a tax rebate. It’s a discussion document on proposed changes to Anti-Money Laundering (AML) supervision fees.
Now, before you switch off and reach for the biscuit tin, let me explain why this matters, especially if you’re running a law firm or responsible for compliance.
What’s Changing with the HMRC?
Here’s the gist of HMRC’s proposal:
- Annual premises fee: going from £300 to £400.
- One-off application fee (for new or lapsed registrations): £400.
- Fit-and-proper test fee: up from £150 to £700. Yes, you read that right, that’s nearly five times higher.
- Sanctions administration charge: a flat £2,000 (capped by penalty value) or £350 for some lower-level failures.
- Approvals fee: staying at £40 per person (small mercies).
The consultation is open until 29 August 2025, which means there’s a short window to have your say. To respond and get involved in this, you should email HMRC with your comments by the deadline of 29 August 2025.
Why Should Law Firms Care?
For many firms, especially smaller practices, these changes could mean a noticeable hit to your compliance budget. Multiple premises? Several people who need fit-and-proper tests? The costs can stack up quicker than you can say “source of funds check”.
And remember – these aren’t optional extras. If you’re under HMRC’s supervision, these fees are part of keeping your AML registration valid. No registration, no business.
What This Means for Compliance
Here’s the thing: as the cost of staying compliant rises, it’s tempting to see AML as an expensive box-ticking exercise. That’s a dangerous mindset.
Money laundering isn’t just about shadowy international criminals moving millions. It can happen in everyday transactions, and property firms, estate agents and others particularly in high-risk areas like conveyancing, and accountants dealing with tax planning and corporate work, are prime targets.
When compliance is done well, it’s like a really good insurance policy: you hope you never need it, but if trouble comes knocking, you’ll be glad it’s in place.
Where Teal Can Help
At Teal Compliance, we can:
- Help you assess the impact of these proposed changes on your firm.
- Support you in responding to the consultation before the deadline.
- Review your roles and processes to make sure you’re not paying unnecessary fees.
- Keep your AML processes lean, effective, and proportionate to your risk.
Because if HMRC’s going to raise the price of the ticket, you might as well make sure you’re on the right train.
HMRC & AML – The Bottom Line
Yes, these proposed fee hikes will sting a bit, but the bigger picture is still the same. Strong AML compliance protects your firm, your clients, and your reputation.
So, read the consultation, work out what it means for you, and do submit your feedback via their email to the HMRC.
If you need a hand, we’re here, biscuits and all. Remember, we have our ASK TEAL service which is perfect for times such as this!
Thanks for reading
Simon.
