Dealing with non compliance: Written guidance and direction
Where appropriate businesses should be directed to the Money Laundering HMRC website where they can view MLR guidance.
In addition to the above, once the visit has been completed, officers should put in writing any action that the business needs to take. If officers decide there is no need for a penalty or warning letter then they should issue specific written advice.
Specific written advice is likely to be used in such compliance areas as risk-assessment and internal controls.
The specific advice should take the form of a letter (which is much the same as the warning letter without the penalty warning).
Written guidance and direction will only be appropriate where there is a minor breach caused by mistake or human error. However penalties will be needed where a breach is caused bya failure to take reasonable steps.