ECSH32820 - What to establish

You should carry out the basic checks referred to in the initial review [link to ECSH 32700 Initial review]to understand what to establish when conducting your initial contact.  

During the initial contact, you should establish and record the following information: 

• whether or not the business is a relevant person under Regulation 8 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)  if not, a visit isn’t needed and the business needs to deregister) 

• who is responsible for compliance with the MLR 2017 and the roles and responsibilities of staff. This is so that you can ensure that all relevant beneficial owners, officers and managers (BOOMs) have passed theappropriate Approval/Fit and Proper test and that you speak to the right people   

• who will be present during the compliance check: this could be the business owner, nominated officer,other Boomsand members of staff within the business, as well as any external advisors or legal representatives 

• whether there is anything about their health or personal circumstances that may make it difficult for them to deal with this check so that you can help[Link to ECSH 32926 Extra Support]  

• what the business activities involveto gain an understanding of the overview of the business 

• what the business model is [Link to ECSH 33120 Understanding business activities] 

• who the business’s clients or customers are 

• where transaction or client records are held 

• (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

• whether the business is happy to communicate by email (See the operational guidance on [Link to ECSH 32812 By email] 

• whether the business has acurrent written risk assessment (RA) and policies, controls and procedures (PCP) documents and when they were last updated 

• if so, is the RA and PCP held digitally and how long it would take for the business to send it to you. You should consider what would be a reasonable time frame given what you know about the business from your initial review and initial contact, ensuring that it is appropriate.  

There is further information regarding RA and PCP documents in ECSH 32825, Information and documents requested before an intervention.