MLR3C10170 - Business sector specific Guidance: Money Service Businesses: Compliance with Directions under Schedule 7 Counter-Terrorism Act 2008
Under the terms of this legislation HM Treasury can issue directions that apply to Money Service Businesses. The directions, which are published on the HM Treasury website, either prevent them from carrying out business with named individuals, organisations and countries that are perceived to pose a threat to the security interests of the UK or place monitoring and/or reporting requirements on such business. Detailed information on this can be found in Appendix 7 Anti-Money Laundering Guide for Money Service Businesses.
When visiting a Money Service Business the compliance checks should establish that the business is complying with directions that have been issued by HM Treasury. The compliance checks should include the following.
- Is the business registered with HM Treasury to receive email notification of the directions? Businesses and Visiting Officers should register to receive the alerts by contacting http://www.hm-treasury.gov.uk/fin_crime_mailinglist.htm
- As part of its risk-based approach has the business taken appropriate measures so that it is able to identify transactions that come under the terms of a direction? For example do computerised transaction records have in-built identification protection? What systems are in place for manual processes?
- Have staff employed in the business been trained in their responsibilities following the issue of a direction?