ECSH45780 - Fit and proper and approvals: contents: operational guidance: authorisations decision maker roles explained

The administrative officer is responsible for:

  • Ensuring all fees have been paid by the business and raising any missing charges.
  • Clearing any administrative 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 administrative 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 a MSB or TCSP.
  • Issue F&P determination letters.