MLR3C5100 - The scope of our supervision: Components of compliance check

To ensure that compliance checks are appropriate under the risk-based approach, Compliance officers should take the following steps when carrying out all types of Interventions:

• focus on the risks identified by the RTT
• decide what appropriate checks need to be made
• plan the intervention effectively
• check that the information held on the HMRC register is correct
• check that the right people within MSBs and TCSPs have undergone the fit and proper test
• ask the business to explain how their risk sensitive anti-money laundering policies and procedures work
• answer any questions the business may have on their legal responsibilities under anti- money laundering legislation
• test that risk sensitive policies, systems and procedures are in place
• test that systems and procedures are operating in accordance with the policy
• test transactions and review customer files to check if appropriate measures for customer due diligence, ongoing monitoring and suspicious transaction reporting have been followed
• check that the business is aware of the simplified due diligence and is operating it where appropriate
• record the information obtained
• evaluate the findings
• explain any areas of concern and agree any action that the business needs to take