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HMRC internal manual

Money Laundering Regulations: Compliance

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


Transaction record may be incomplete so check transaction details on bank records such as paying-in slips, statements or faxes and emails against daily transactions to confirm that:

* all transactions have been recorded
* monies are going to the destinations recorded
* The following types of transaction are ones that businesses should consider to be a cause for additional scrutiny:
    * Foreign exchange transactions that are followed within a short time by a transfer of funds, particularly to or through a location of specific concern (e.g. FATF non co-operative countries). Confirm that the Nominated Officer is aware that particular attention should be paid to these types of transactions
    * Customers presenting uncounted money to exchange. When counted the amount comes to just below amount which would trigger identification or reporting requirements
    * Customers requests high domination notes such as €100, €200, and €500 notes or $100 US notes
    * Customers who exchange large amounts and do not negotiate a preferential rate of commission.
    * Customers, especially in central and southern regions of England, who exchange large quantities of Scottish bank notes. (This content has been withheld because of exemptions in the Freedom of Information Act 2000) 
    * Customers with inconsistencies in their story when the business carries out ID checks. For example, regarding previous or current country of residence, country of issue of the passport, countries visited according to the passport, and the documents furnished to confirm name, address