Business sector specific Guidance: Money Service Businesses: Specific Compliance Checks at a Cheque Cashers
Records can vary depending on the type and size of the business.
However, it is usual to see the following documentation:
* customer’s ID * mandate forms * computerised customer account * daily summary records * statement from franchisor detailing cheques banked * banking records (for example bank statements)
Potential failures/weaknesses under MLR 2007
Due to the commercial procedures in place the risk of money laundering is low.
However, there are common failures/weaknesses and these are as follows:
Regulation 20 - Documented procedures usually concentrate on the commercial risks and therefore may not meet the requirements of regulation 20.
Regulation 8 - No evidence of ongoing monitoring of a business relationship. ID not refreshed and no evidence transactions have been scrutinised.
Regulation 14 - Business may accept cheques made payable to a limited company without applying any due diligence measures.
Regulation 21 - No documentation evidencing staff have received appropriate training.
The following show what type of transactions is normally accepted. It is not a definitive list but it contains information about the types of cheque that a cheque casher will usually consider cashing or is unlikely to cash.
Acceptable Types of Cheque Drawers (company, body or person who makes out the cheque)
|Private Sector||Local Government||Central Government|
|Private Limited Companies||Metropolitan Boroughs||HMRC|
|Public Limited Companies||County Councils||DWP|
|Unlimited partnerships||District Councils||HM Paymaster General|
|Individual Business Accounts||Town Councils||Post Office Counters|
|Pension Funds||Agencies of the above||Any Nationalised Industry|
|Bank or Building Society||Any Government Agency|
|Mutual Company of any kind||Giro Cheques (where crossed)|
Unacceptable types of Cheque Drawers
Most cheque cashers will not be willing to accept cheques where the drawer is:
* a private individual unless they are also the payee. * a giro cheque with an open crossing (these can be freely cashed at a Post Office). * Limited companies.
Acceptable type of Cheque Payee (person cashing the cheque)
* private individuals * married couples or joint payees * partnerships.
Unacceptable type of Cheque Payee
* Cheques in favour of a private individual where the drawer is also a private individual unless they are the same. * Giro cheques with an open crossing (these can be freely cashed at a Post Office)