ECSH32841 - Advance notice of a visit
Most
businesses should be able to accommodate a visit if they are given at least a
week’s notice. However, there may be good business reasons for delaying a visit
for longer. You must listen to and consider carefully any representations made
by the business. You may need to carry out more than one visit, or
different types of interventions, see ECSH32600, to complete your compliance check, and this
should be discussed with the business in advance. Where appropriate to do so,
consider the guidance in ECSH32915 before
speaking to the business to arrange a visit.
You must not request or make a visit at a time that you discover will be
particularly inconvenient. For example, it is quite common for art market
participant (AMP) galleries to close for the summer and accountancy service
providers (ASPs) to be busy at the end of the tax year. You should also
consider public holidays and religious holidays that people may want to
observe. Normally, you should telephone the business with the aim of agreeing a
convenient date and time, following the guidance in ECSH32810 and ECSH32820.
Consider a suitable start time for the meeting, taking into consideration your travel arrangements, and how long you expect the meeting to last, so it finishes at a reasonable time. Between 9am and 11am is usually appropriate, but it will depend on the circumstances of the visit. Consider the business’s opening or working hours; some money service businesses (MSBs) may open later so they can close later, in line with customer footfall.
The arrangements agreed with the business must be followed up in writing, using the appropriate “confirmation of visit” template for the type of case, which can be found in the in the Knowledge Library.
It would be unusual for a confirmation of visit letter to be issued without
first attempting to contact the business to discuss its supervised activities,
see ECSH32810.
If you have been unable to contact the business, follow guidance in ECSH32835.
Normally you will agree a date and time with the people you need to speak to
during the visit, giving at least 7 days' notice. You must have good reason to
ask the business to agree to a visit with less than 7 days' notice and explain
it to them. You should also consider your own time management, how long it will
take to book travel, accommodation, if necessary, arrange a second officer to
attend with you, and complete all essential preparation for the meeting.
It may be that the officer who telephones the business to arrange the visit and
issues the confirmation of visit letter is not the officer who is actually
going to carry out the visit. The officer arranging the visit should make clear
to the person representing the business that the HMRC officer/s will identify
themselves by name at the start of the visit and will carry
identification.
It may help to provide the business with a link to published guidance on how HMRC checks on businesses registered for money laundering supervision on GOV.UK.
Arranging a desk-based intervention
If you are arranging a desk-based intervention (DBI), you should consider:
- Who will be present during the call, from HMRC and the business.
- Who will be taking notes.
- An appropriate time for the call to take place.
- How long the call will take.
When considering an appropriate time for the call, you should try to agree a time when the DBI can be done in one go, taking into consideration lunch breaks, childcare or other personal appointments. Alternatively, you may need to make arrangements for a further call.
You should explain that you will call the business at the agreed time and date and check that you have the best telephone number to call them on, or agreement to use MS Teams following the guidance. For more guidance on DBIs see ECSH32610.