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HMRC internal manual

Money Laundering Regulations: Compliance

Appendix 2 Unannounced Visits: At the visit

At the visit:

  • Always identify yourself and the purpose of the visit
  • Ask the trader if they conduct MSB activities or if they accept high value cash payments for goods and if they are registered
  • If the trader is registered record the MLR number and check that the registration details are accurate.
  • Then ask them if you can make an appointment to check their understanding of the Money Laundering Regulations and that they are complying with them.
  • If the trader will not arrange an appointment for a visit point out that if they do not agree to a visit we could take action through the courts
  • Record details of each visit in a book with numbered pages stating the time and place of the visit and include the names of all Officers present.
  • Record the name of any person spoken to at the visit and what was said
  • Record the type of money service business being operated if this is relevant and the name of the MSB or High Value Dealer.
  • Attempt to establish how long they have been trading from the premises and if they have previously traded from any other premises.
  • If you are provided with information from another person regarding the trader relating to a possible criminal offence or regulatory breach (including any offences that may ultimately be dealt with under ‘civil’ provisions) or regulatory breach you should follow the HumInt procedures
  • You should bear in mind that an unannounced visit may cause the trader to feel nervous, alarmed or even confrontational and this will require careful handling. When interviewing the business you should ensure that you are firm, persistent and polite. Details of your visit should be recorded in your notebook and the MSB or HVD asked to read, agree and sign the entry.

Trader refuses access to premises

In most instances businesses will be co-operative, but in the unlikely event that a business is reluctant, you should try to persuade the business to allow access in their premises. You must remain polite, yet firm. Explain the law and powers under MLR 2007 Regulations 37 [1] Power to require information from, and attendance of, relevant and connected persons.

In circumstances where the trader is being hostile, remain courteous, firm, and confident. You should be prepared to leave and report the full facts to your line manager