Having an out of date webinar on compliance obligations available on the HMRCs website is one thing. Knowing it is out of date and leaving it there is another.

But to send out an email alert on October 24 to all those who subscribe to HMRCs email alerts advising them of the availability of a webinar for estate agents on conducting Customer Due Diligence (CDD) to comply with the new 2017 Money Laundering Regulations when it is the old out of date webinar takes it to another level!

After four months of waiting there is a strong possibility that numerous agents signed up for it. It is delivered immediately to your computer, but it is still the old version, even though it clearly states that it is “A webinar about the new regulations on money laundering which were introduced in June 2017” and your average agent is likely to assume it is providing correct legal advice.

It provides misleading and wrong information about compliance to the new Regulations, because it was recorded back in early 2017 before the new Regulations were introduced.

Amongst other things the webinar indicates that conducting CDD on your client is an obligation and it goes on to say that conducting CDD on buyers was “Good Industry Practice”! Since June 2017 conducting CDD on buyers has been a statutory obligation, not simply good practice.

Amusingly it states that HMRC will be keeping the webinars as up to date as possible!

I feel duty bound to quote an old favourite: Is this a breach of the Trade Descriptions Act?

It will be interesting to see how HMRC will handle any agent who hasn’t been conducting CDD on buyers, because of the content of this webinar? Perhaps no penalties will be imposed!

EYE asked HMRC about this ‘latest’ webinar, and last night a spokesperson told us: “HMRC is in the process of updating the content of the webinars it undertook prior to the introduction of the new Money Laundering Regulations in June 2017.

“This work is due to be completed by the end of December.

“When the new Regulations came into force, a message was added to the GOV.UK webinar page, stating that there may be some differences in relation to the content covered. In addition, in July and October this year, we ran two new webinars covering the new Regulations.”

Both of these recordings, said the spokesperson, are on GOV.UK

* David Beaumont runs EYE’s free compliance helpline, available to subscribers at no charge.

If you would like any up to date advice on compliance with Money Laundering Regulations or any other compliance requirement you can call David Beaumont, managing director of Compliance-Matters, 0161 727 0798