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HMRC internal manual

MLR1 Penalties Guidance

Penalties guidance: calculating penalties: points to consider: during the visit

During the visit

During the visit establish whether a breach of the Regulations has taken place or if there are any material failings or weaknesses in the anti-money laundering policy and procedures which, if not corrected, are likely to lead to a breach. If there is none, no further action is required other than to give any assistance that is requested.

When a breach has been identified, points to consider:

  • is there clear evidence that the Regulations have been breached
  • is there any evidence of a primary money laundering offence or have the criteria for a criminal investigation been met
  • does the failing fall within the criteria for a penalty