ECSH32905 - Duties of supervisory authority: how we check compliance: operational guidance: planning the intervention: results from initial review

To plan your compliance check efficiently, you need a clear idea of what you are trying to achieve.

PERCET is often used as an acronym for how to carry out a compliance check. This stands for Plan, Establish, Record, Confirm, Evaluate, Test.

Planning helps you to:

  • establish the areas of risk to be considered and how they will be addressed (see ECSH33205 Checking risk assessment and management)
  • conduct your compliance check in an organised and structured way
  • make the best use of time and resources and avoid any unnecessary or duplicate requests to the business case
  • build up a picture before you contact the business

Once you’ve gathered your information (see ECSH32825 Information and documents requested before an intervention), you can review the material. Consider the below to help you plan your approach:

  • was the business selected as part of a campaign, or is it a routine compliance check (see ECSH32705 Project Initiation Document (PID))? Does the case meet the rejection criteria in the PID? If so, you should speak to your manager to reject the case.
  • what risks have been identified on your Standard Information Package (see ECSH32710 Standard Information Package (SIP))?
  • does the SIP contain enough information for you to conduct your checks?
  • is it a Large Business or critical case (see ECSH32625 Visits to a HMRC Large Business and ECSH34115 critical reporting)?
  • were there any breaches arising from a previous compliance check?
  • what information do you already have about the business? This includes the business structure, locations, activities, Beneficial Owners, Officers and Managers (BOOMs – referred to as “Responsible Persons” within the SIP and shown on ETMP) which the business will have submitted on their application form (see ECSH32731 ETMP)
  • if you're going out of the office, are there any travel and accommodation arrangements to make, or health and safety considerations (see ECSH32929 Officers personal safety)? For guidance on booking travel, see Booking Travel and Conferencing.
  • if you consider there is a serious risk to your health and safety by carrying out a face to face visit, you must speak to your manager who will need to get agreement from the G7 Operational Lead to change the visit to a desk-based intervention (if that is the approach set out in the PID)
  • who will you need to speak to within the business to get an accurate picture of compliance (this may not just be the Nominated Officer)?
  • will there need to be agent or branch visits conducted?
  • who needs to be involved or informed about the compliance check? For example, single point of contacts (SPOCs) and colleagues within your team, Sector Specialists, Customer Compliance Manager (CCM), specialist staff such as auditors or data handlers. How will you coordinate with them?
  • what background information and analysis about this type of business or the relevant sector is there? See ECSH32935 Tactical and Information Packages (TIPs), internal risk assessments held within the Knowledge Library Home, sector guidance found on GOV.UK

Money Laundering Regulations and National risk assessment of money laundering and terrorist financing 2020 and National risk assessment of proliferation financing

If you see a charge on the account for the Economic Crime Levy, you do not need to take any action as this is dealt with by another department. For more information see Economic Crime Levy

Planning is an on-going process throughout the course of the compliance check. It must be evidenced in Caseflow (see ECSH34105 Caseflow and case trackers). There isn’t a template to complete, so how you record it is up to you, but it must be retained. You may also adapt generic aide memoires to help with planning your interview – see ECSH32940 Using aide memoirs and topic plans. If new information or new risks are identified or received, you will need to amend your plans accordingly. If, after carrying out your initial review, you consider that an intervention is no longer needed, speak to your manager.