ECSH33740 - Records testing: requesting bank statements

During a compliance check, you may need to review bank statements from any account used by the business (including personal accounts).

Before requesting the bank statements, you should ask questions about the bank accounts the business holds and/or uses. You should establish what each bank account is used for, who the signatories to the accounts are, as well as asking for details of members of staff who have access to the bank statements, for example for monitoring purposes.


Reasons for requesting bank statements

You should consider the reasons why you want to review bank statements and what you hope to achieve by obtaining them. Reasons may include:

  • Testing financial soundness.
  • Confirming what the business has told you during the compliance check matches with the activity within the bank statements.
  • Checking whether a business carried out relevant activity during a relevant period.
  • Identifying any unregistered relevant activity (such as other sectors the business is not registered for).
  • Identifying any red flags and risk of money laundering, terrorist financing and proliferation financing (ML/TF/PF).


Requesting bank statements

When asking to see bank statements, you should consider the period you would like to review. You may need to consider:

  • Whether the business has the statements available, or if it will need to request copies from their bank – establish how long this will take.
  • The relevant period you are reviewing.
  • Any days/months which relate to specific transactions you are testing.
  • Busier times of the year from the information gained throughout the compliance check.
  • Any events or religious festivals which may impact the levels of business activity.
  • Whether your request is reasonable and proportionate to the risks of ML/TF/PF.

Along with business bank account statements, you may consider requesting personal bank statements if you establish that ta personal account is used or has been used for business purposes. This will depend on the specific circumstances of your compliance check and the bank accounts the business uses.

 

Reviewing bank statements

You should check:

  • That there are no parts of the bank statements missing.
  • That pages run in number or date order.
  • Whether the activity in the bank statements is credible.
  • Whether the activity in the bank statements corresponds with the activity you have been told about.
  • Whether the activity in the bank statements confirms what you expect to see, for example, regular utility bills and payments to suppliers.

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

Recording information from bank statements

When recording pertinent information from bank statements, you should include anything that may be used in evidence, and it must be clearly referenced so the statement or transaction can be replicated. You may want to note down:

  • The account name, number, and address of the bank account that you are looking at.
  • The date of the statement in question.
  • the page number when referencing a specific transaction.
  • The opening and closing balance (if the figures are almost identical, there is a risk this could indicate possible money laundering).
  • Direct costs as these can be removed when calculating a penalty.

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