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HMRC internal manual

Money Laundering Regulations: Compliance

HM Revenue & Customs
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Appendix 2 Unannounced visits to unsupervised businesses (policing the perimeter): At the visit

  • Always identify yourself and the purpose of the visit
  • Agree to conduct a visit at a convenient time for the business if they have prior arrangements.
  • Help the business understand anti money laundering legislation
  • Encourage the business to view the MLR8 notice and contact the National Advice Service for a copy of the MLR DVD
  • Where you suspect the business is operating as an MSB ask the business if you can test purchases
  • 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 and agreed
  • 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 business 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 business 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.