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HMRC internal manual

Money Laundering Regulations: Compliance

HM Revenue & Customs
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Business sector specific Guidance: Money Service Businesses: Currency Exchange Offices and Money Laundering Risks.

The following list (not necessarily in order of importance) sets out factors which are likely to cause suspicion that a business might be being used for Money Laundering activity.

  • Business does not carry out any checks when customer pays in cash because of staff ignorance.
  • Business does not carry out any checks on occasional customers making them more vulnerable to money laundering.
  • Business accepts a cash payment for currency that does not fit with what the business knows about the customer’s destination
  • Business may accept payment from the customer in used notes or small denominations.
  • Cruise ships and ferries may not seek appropriate ID on cruises (e.g. world cruise) where a series of transactions may exceed €15,000 as they assume traveller will not exceed this sum
  • Cruise and ferry staff may not obtain sufficient training where substantial amounts of cash are being exchanged in high risk countries
  • The Nominated Officer may not be based in the UK on cruise ships or ferries. The nominated officer may reside in the Republic of Ireland for a Currency Exchange Office based in Northern Ireland.
  • Hotel staff may not check ID if it was recorded in booking in. However, booking in checks may not satisfy MLR requirements or staff may assume that the room key holder is the resident.