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With a money transfer firm being fined millions for money laundering failings, Nicola Sharp of financial crime specialists Rahman Ravelli outlines the risks such companies face.

Author: Nicola Sharp  29 April 2021

A money services business has been fined £4.5 million for breaching anti-money laundering regulations.

HM Revenue and Customs (HMRC) has announced that it has imposed the penalty on Irfan Exchange. In a notice of the fine, published by HMRC, it states that the company failed to carry out risk assessments, did not implement proper anti-money laundering procedures and was not carrying out effective due diligence. The company also failed to properly keep records.

Irfan has not filed an appeal against the fine, according to HMRC’s website. The company offers services including international transfer of funds and foreign currency. 

Any company that provides financial services which include the use of cash payments should have money laundering procedures of the highest standard in place. There are obvious money laundering risks associated with cash payments – and these risks have to be addressed. 

It is no coincidence that the only other company fined more than £1 million by HMRC since 1 February 2020 was another firm that offered money transferring services. That company, MT Global, was fined £23,828,092 and is appealing the penalty notice.

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Nicola Sharp


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Nicola is known for her fraud, civil recovery, arbitration and business crime expertise, her experience of leading the largest financial disputes and multinational investigations and her skills in devising preventative measures and conducting internal investigations for corporates.

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