ECSH32835 - Initial contact: What to do if there is no response to initial contact

If unsuccessful attempts have been made by Phone (Teams call and your work mobile (if you have one), at different times on different days), consider using open source/HMRC data to try to find another way to engage the business.

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You can send a Confirmation of Visit letter by post to prompt contact from the business, see ECSH32813 and ECSH32841 -  Advance notice of a visit. However, use of information and inspection powers afforded by The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) may be more appropriate.

You could consider getting a drive by/walk by conducted to see if the business is still operating. This is, as the title suggests, just a walk by or drive past the appropriate address. If you intend to enter the premises or speak with anyone in the business, that is an unannounced visit which must be conducted in an appropriate way with appropriate powers. Before arranging a drive by/walk by or unannounced visit, you must ensure you read the additional information on drive bys/walk bys below and for information on unannounced visits, see ECSH32620.

Drive by/walk by

A drive by/walk by may be appropriate to see if a business is still operating from the address   where:

  • it is not on our register, or no contact has been made by you or teams in Economic Crime - Supervision (EC-S)
  • it is registered for anti-money laundering supervision, and whilst working your case you have been unable to make contact with it or the contact has unexpectedly stopped

Before considering a drive by/walk by, you must:

  • use open source and HMRC data to check whether a business is still trading or is operating from another address
  • consider whether there are any other ways to engage with the business
  • consider if a drive by/walk by would be an effective use of time and resources

If you have considered all the available options and decide that a drive by/walk by may be appropriate, you should consider who is best placed to do the drive by/walk by. This may be a member of the compliance team geographically closest to the business. Remember, it may not be an effective use of time or resources to travel far distances just to conduct this. You should discuss this with your Team Leader and the Team Leader of the relevant team to make arrangements.

The results of the drive by/walk by should be recorded as a notebook entry, as soon as is practically possible – see guidance at ECSH33025 – providing as much detail as the officer carrying it out can provide, such as:

  • any signage or business name seen
  • whether shutters were up or down, or doors/windows boarded up
  • whether the premises was open and if customers were seen in or entering the premises
  • unopened mail visible by the door

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If contact can’t be made, discuss how you will resolve the compliance check with your manager, following the Standard Work Instructions and the guidance at ECSH 34000, Outcomes.