Mathews t/a Coast & Country v Revenue and Customs (MONEY LAUNDERING - Breach of registration requirements in terms of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 - whether penalty should be imposed) [2025] UKFTT 1124 (TC) (19 September 2025)

Executive summary

The First-tier Tribunal (Tax) dismissed Ashley Mathews t/a Coast & Country’s appeal against an HMRC civil penalty of £13,000 for trading as an estate agency business while unregistered under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The tribunal held that a penalty should be imposed, accepted HMRC’s position that the relevant Government Gateway account should be checked, and found the penalty proportionate.

Key points

• Parties: Ashley Mathews t/a Coast & Country v HM Revenue and Customs
• Issue: whether a civil penalty should be imposed for breach of MLR 2017 registration requirements for an estate agency business
• Holding: appeal dismissed; penalty of £13,000 upheld
• Reasoning: the appellant traded while unregistered after the registration had expired/cancelled, and HMRC’s reminder notifications were sent via the Gateway account
• Reasoning: the tribunal accepted HMRC Guidance on checking the Gateway account and found the penalty proportionate
• Sanctions / AML angle: the case sits within the UK’s anti-money laundering and terrorist-financing supervisory regime, confirming strict enforcement of registration compliance

Why it matters

This decision shows that UK AML supervisory obligations tied to terrorist-financing prevention are enforced through automatic reminders, cancellation, and civil penalties, not just substantive investigations. For sanctions and national security audiences, it reinforces that failure to maintain registration can itself trigger adverse regulatory action even without any allegation of underlying laundering conduct.

Implications

For compliance teams, the case underscores the need to monitor HMRC anti-money laundering supervision accounts directly and to treat renewal deadlines as operational controls, not administrative formalities. For enforcement and litigation strategy, it supports HMRC’s use of published guidance and internal penalty frameworks to justify proportionate civil penalties where a regulated business remains unregistered for an extended period.