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HMRC internal manual

Money Laundering Regulations: Compliance

Business sector specific Guidance: Money Service Businesses: Basic Compliance Checks at a Currency Exchange Office

Credibility checks

  • Establish how long the business has been trading.

    • If it is a new business and the proprietor / Nominated Officer has previously been involved with a money service business, ask what position he/she held and the reasons for leaving.
    • If the proprietor/Nominated Officer has been involved in money service business previously you should expect a higher level of knowledge of MLR, POCA and Terrorism Act.

Security measures

* Look at what security measures are in place at premises such as CCTV and record details.
* Premises with video cameras may be used to a much lesser extent by money launderers.
* The type of security measures installed may give an indication of the level of transactions carried out.


* Find out if the business is renting the premises or owns it outright.
* If the premises are rented ask how long the lease term is, the amount of the rent and how frequently it is paid. This may give an indication of the likelihood that the business will continue to operate.
* Consider whether it appears likely that the business support the cost of the accommodation.
* Find out how many entrances there are to the premises and how many phones/faxes there are. Make a note of the numbers.