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HMRC internal manual

Money Laundering Regulations: Compliance

Compliance checks involving visits: Officers Notebooks

The findings of a compliance visit must be recorded fully in the Officers Notebook. Ultimately this could be used as evidence at a Tribunal or in Court. Officers therefore should use the following guidance when completing the Notebook:

  • Always use ink never pencil when completing the notebook
  • Never use correction fluid.
  • Mistakes should be crossed through with a single line, initialled, and the correct words inserted immediately after the error. It should be possible to see what has been struck through. Overwriting or writing above the error is not acceptable.
  • Avoid leaving blank spaces between words, and keep empty lines to a minimum.
  • Notes in the book should be as soon as the information to be recorded is obtained or made ASAP after events as possible, and certainly on the same day.
  • Corrections may be made after the visit. They are to be in red ink, dated and timed.
  • Later additions may be made on a separate page and cross-referred in red to the original entry.
  • Use a separate page for each visit. At end of notes, use a freehand Z to strike out all unused blank space on the page.
  • Any notes made other than in the notebook should be attached to the Notebook but this practice should be kept to an absolute minimum.
  • Include no information of a security nature ((This content has been withheld because of exemptions in the Freedom of Information Act 2000) , own/colleague phone numbers).

The following details should always be recorded in the Notebook:

  • name and registration no of the business.
  • date, time and place of visit.
  • name and position in the organisation of all the relevant people that have been seen by Officer.
  • name of any other Officer present during the visit.
  • facts identified at the visit
  • visit report should reflect what is in the notebook.

Where separate schedules etc are used, cross-refer them in the Notebook, and state where it is stored (e.g. in trader’s folder; held by officer etc).

Most of these details will be obtained at the interview.