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HMRC internal manual

Money Laundering Regulations: Compliance

Business sector specific Guidance: Money Service Businesses: General Compliance checks at a Money Transmitters.

The following checks should be carried out.

* Confirm that the business name, address and legal entity have been correctly registered and that the number of premises in the business’ records matches with the number on DTR.
* Confirm the names of the key personnel within the business (owners, directors and Nominated Officer) and check that all relevant persons have applied for and received confirmation of their “Fit and Proper status”. 
* Establish how long the business has been trading.
* Find out if the trading premises are owned or leased. If the premises are leased ask how long the term of the lease is and if it is due to expire whether it is intended to extend the term and continue to trade.
* 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. An experienced proprietor or Nominated Officer should have a higher level of knowledge of MLR, POCA and Terrorism Act. 
* Look at what security measures are in place at premises i.e. CCTV and record details. Businesses with security systems in place are less likely to be used by money launderers.