HMRC has updated its website to reflect the changes the MLRs have brought and, in particular, the new classes of entities that fall within the regulated sector. It will issue further guidance shortly, but has confirmed that:
- MSBs and trust or company service providers who apply to register from 10 January onwards cannot carry out relevant activity until HMRC has approved their registration;
- letting agencies will be able to register with HMRC from May 2020 (but must be compliant with the MLRs from 10 January); and
- art intermediaries can apply to register already.
All relevant firms must be registered by 10 January 2021. HMRC also says it will take account of the short lead-in time to the MLR changes when assessing non-compliance with new requirements.