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HMRC internal manual

Money Laundering Regulations: Compliance

Trust or Company Service Providers (TCSPS): Compliance checks at a visit to a nominee services provider

When visiting a nominee services provider it is essential that the business has carried out effective anti money laundering procedures to mitigate the substantial risks discussed in the preceding paragraph. Compliance will be demonstrated by showing that effective measures have been taken with regard to customer due diligence so that the identities of the company directors and shareholders are known. A full risk assessment should be carried out which establishes the following;

* the reasons why the owners want to appoint nominees
* the identities of the beneficial owners
* the trading activity of the company
* the levels of turnover
* sources of working capital
* location of customers (sales)
* location of suppliers (purchases)
* openness of the client and whether information and explanations are supplied willingly.