MLR3C10505 - Trust or Company Service Providers (TCSPS): Compliance checks at a visit to a recruitment agency or outsourced executive supplier

When visiting a recruitment agency or headhunting firm it is only necessary to confirm that the business has performed some basic checks on their client. This should involve establishing the identity of the client, the type of activities it is involved in and a general picture regarding its trading.

As outsourced services involves the placing of individuals within key positions within a company or partnership the greater risks means that firms that operate in this area must carry out much greater anti money laundering measures. These should include:

• carrying out full customer due diligence measures to identify the client
• carrying out a risk assessment of the business based on its trading activities, looking at transactions and monitoring them for suspicious activity
• training staff where the firm has a panel of persons that it supplies to businesses so that they can identify suspicious activity and know how to report it.