MLR3C5250 - Scope of our supervision: Activity on possible non compliance

HMRC may carry out a desk based intervention on a business where we have specific information which suggests that there is a chance that the business is non-compliant.

HMRC will ask a business for information either by phone or in writing about, its customers and its anti-money laundering policies and procedures to address any specific risks we have identified.

HMRC may also contact some businesses to help us identify good practice in a particular business sectors or situations. Contact will also help us develop or refine ways of identifying non compliance by similar businesses.

HMRC may also in some cases visit the premises when we have specific information which suggests that there is a possibility that the business is non compliant but where a desk based intervention is not appropriate.

HMRC will regularly review our supervisions and interventions with a view to considering the extent to which it would be appropriate to remove or reduce the burdens they impose on relevant businesses.

Although MSBs as a sector are high risk, the fit and proper test has been developed to prevent high risk individuals from using these businesses to launder money. The main risk in relation to cheque cashers was the risk that the business itself was being used to launder money. As a result of the f+p test cheque cashers have become low risk and HMRC will review our risk assessment to take account of this. Where bureaux de change and money transmission take place at cheque cashers HMRC will focus our checks on these high risk businesses.