ECSH32915 - How to address risk

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Consider which risks must be resolved during a face to face visit or whether some risks can be resolved by a phone call [link to ECSH 32600 Types of intervention]. Remember, you cannot change the type of intervention from face to face to desk-based unless agreed by operational G7 Compliance leads. Multiple visits may be needed in order to fully address all of the risks.

is there conflicting information held in different places that needs addressing?

can the risks be addressed by reviewing the risk assessment and discussing the business’s understanding of risks to their business?

can the risks be addressed by transaction testing or reviewing the business’s systems? [link to ECSH 33700 Records testing]

does the combination of business activities fall within high risk sectors?

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is the business still operating? This can be checked on Companies House [ECSH 32734 Companies House]

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is information on the business’ application form missing or inaccurate? Do you need to inform them they need to update their details? If so, see Sanctions for non-compliance: financial penalties: financial penalties framework: type 3 penalties (sharepoint.com)

Consider if any of the information provided on its application is false and misleading? See ECSH 85745, How to evidence a business has provided false and misleading information

Having considered these, you will then need to think about:

who do you need to speak to?

what records might you need to see on the day of the visit to test policies, controls and procedures are working in practice?

how long is it going to take you?

Some risks might be able to be resolved by phone but generally, face to face visits are conducted due to HMRCs supervisory requirements to effectively monitor its supervised population, on a risk-based approach.This might change throughout the life of the case; what you thought was a quick phone call could turn into a full face to face depending on the risks 

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