ECSH32605 - Telephone call


Introduction 

Depending on the circumstances of the case, a telephone call may be appropriate when:  

  • checking the business’s compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) under an aspect campaign such as a follow up to a previous warning or penalty [ECSH 32600 Types of intervention] 
  • conducting a fact-finding interview or checking information, for example when determining an application for registration  

You may have conducted a face-to-face visit and have some more questions following your review of the information or record testing you have carried out. You should consider if it is reasonable and proportionate to conduct a telephone call rather than conducting a second visitor corresponding solely by letter or email (where the protocol is in place). 

What you need to consider  

During the telephone call, you should consider: 

  • setting parameters such as what would happen if connection fails, or the telephone call drops 
  • the pace and tone of your speech 
  • the language you use 
  • possible language barriers [ECSH 32927 Overcoming language barriers] 
  • the timing and duration of the telephone call 
  • the pace of the notetaker 

You should advise on the approximate length of the telephone call and offer regular breaks. Remember, as you may not be able to see the person you are talking to, you should ensure they have regular opportunities to ask questions.  

Who is present? 

Conducting a telephone call or Microsoft Teams call differs from face-to-face visits in that you may not be able to see who is present. You should consider whether you conduct a Microsoft Teams call with cameras on or off. You should be aware that some businesses may not have equipment which allows use of cameras. 

It is important to follow data security measures to ensure you are speaking to the correct person, for example by asking the individual to confirm some personal information, such as their date of birth. It is good practice to ask if there is anyone else present in the room or listening in. If so, make sure you confirm their identity and their reason for being there. You should identify who is speaking if there’s more than one person present in a room (rather than dialled in separately) to ensure you can record who said what in your contemporaneous notes of the call. 

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You should explain who is present from HMRC and their roles and responsibilities during the call, such as a second officer taking notes of the meeting or an observer. You should also ask the business to tell you who is present on the call from their side and their roles and responsibilities. You may find that a business has an accountant or advisor present [ECSH 33015 Working with advisors]. 

You must explain that you may be disclosing confidential or sensitive information and check that the business is happy for the call to continue with the persons present. 

How and where to conduct a telephone call? 

To arrange a Compliance intervention by telephone call with a business, see the guidance at [ECSH 32841 Arranging a visit]. 

For a different type of call such as a fact-finding interview or to check information with a business, consider whether you should pre-arrange the telephone call to ensure the business is available. You may need to consider how long the call is likely to take and whether you will need a notetaker present. If so, you should confirm the date and time of the call with the business either by letter [ECSH 32813 By letter], email (where email protocol is in place) [ECSH 32812 By email] or phone [ECSH 32811 By telephone]. 

Sometimes a telephone call does not need to be pre-arranged, for example,when making your initial contact with a business by telephone. 

You should consider your location when you conduct a telephone call with a business. For example, a quiet space where you will not be interrupted and cannot be overheard if discussing sensitive and confidential information. This is particularly important if making a call when working out of the office or at home.