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HMRC internal manual

Money Laundering Regulations: Compliance

From
HM Revenue & Customs
Updated
, see all updates

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