ECSH33715 - Records testing: transaction testing

You must keep a record of what records you view during the course of an intervention; with details of the tests you applied on them and your findings. Include this in your notes of meeting.

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

If the business can’t provide any documents at the time of the records testing, record the reasons for this and make a note to remind them to send you them after the meeting. These must be sent securely, with the right protocols in place – see the guidance for Electronic documents and records. If a business claims that the records you need to see are held by a third party, the information powers afforded to HMRC under regulation 66(8) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulation 2017 (MLR 2017) extends to anyone in possession of the document.


Information to capture

Whilst conducting records testing, you must record sufficient information to allow the document you have seen to be reproduced, for example:

  • Passports and visas -note the full name, date of birth, place of birth, passport number, expiry date and issuing office. It may also be necessary to record any restrictions shown on the documents, such as right to work.
  • Driving licence-full name, date of birth, licence number, expiry date and issuing office. It may also be necessary to record the class of vehicles covered by the licence. For example, if you are conducting a compliance check to a business supplying second-hand vehicles registered as a high value dealer (HVD), you would expect to see a driving licence as opposed to other forms of photographic ID, as this also confirms the customer can drive the vehicle away. If the customer isn’t authorised to drive the class of vehicle purchased, it may indicate a beneficial owner whose identity hasn’t been verified.
  • Proof of address -type of document for example utility bill, name of provider, addressee, address on document, date, reference number. For utility bills, it may also be necessary to record the services provided.
  • Electronic verification search -date of the search and any key details relevant to your enquiries, for example, name, address, credit rating, red flags.
  • Shipping documents - consignor, consignee, ship, ports, dates, description of goods and weights.
  • Invoices -invoice number, date, customer name, account number, goods description, and invoice total.

You can find more information about the types of records you may see in ECSH33355 Evidence of verification.

For general guidance on testing customer due diligence (CDD) measures, see ECSH33300.

Any personal data you obtain must be kept securely in line with the General Data Protection Regulation (GDPR).