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HMRC internal manual

Money Laundering Regulations: Compliance

Trust or Company Service Providers (TCSPS): Recruitment agencies, outsourced executives and Money Laundering risks

A recruitment agency or headhunting firm that has been engaged to find and appoint directors on behalf of its clients has no involvement in the client’s financial affairs. It is therefore only necessary for the business to have a basic knowledge of the client’s identity and business activities.

An outsourced company secretary, director or partner appointed to a business carries a greater risk of money laundering. Acting in one of these capacities would mean that the appointed person will have an insight into the financial affairs of the client and may be authorised to conduct transactions with clients. In this position he/she may become aware of involvement by the client in money laundering activity.