ECSH45780 - Fit and proper and approvals: Contents: Operational guidance: Authorisations case worker roles explained

The admin officer is responsible for:

  • Ensuring all fees have been paid by the business and raising any missing charges.
  • Clearing any admin risks (e.g., manually checking ID documents from foreign nationals or querying any application for registrations as an unusual combination of sectors).
  • Checking the business’ website and Companies House registration to ensure that it has included all its Beneficial Owners, Officers, or Managers (BOOMs), premises and services in its application for anti-money laundering supervision.
  • Ensuring that the business has confirmed that it has a Risk Assessment (RA) and Policies, Controls and Procedures (PCPs) in place.
  • Sending data capture letters to BOOMs included in applications from High Value Dealers (HVDs), Money Service Businesses (MSBs) and Trust or Company Service Providers (TCSPs)
  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Authorisations approvals decision maker

The approvals Decision Maker (DM) is responsible for:

  • Ensuring that no new BOOMs have been added to the business’ application since admin checks were conducted.
  • Checking the business’ website and Companies House registration to ensure that it has included all its BOOMs, premises, and services in its application for anti-money laundering supervision.
  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
  • Approving, refusing, suspending, or cancelling a registration.
  • Issuing one or more of the following financial penalties:
    • A trading whilst unregistered (type 2)
    • A failure to notify HMRC of material changes and/or inaccuracies to information (type 3)
    • Failure to comply with a Notice provide information and/or documents under Regulation 66 (type 4)

Further guidance on financial sanctions is available in ECSH82775.

Authorisations fit and proper decision maker

The Fit and Proper (F&P) DM is responsible for conducting the same checks as the Approvals DM above and:

  • Conducts F&P checks using the following systems for all new applications: ICE, JARD, Equifax, Vision, PAYE, and FAME.
  • Consider data capture responses from the business and its BOOMs to decide if they are F&P to provide the services of an MSB or TCSP.
  • Issue F&P determination letters.