MLR3C5460 - The scope of our supervision: Identifying relevant businesses trading unsupervised when required to register with HMRC: Other checks on businesses

It is important to remember that although there are only two supervisors for MSBs and HVDs, there are more than twenty possible supervisors for the TCSPs and ASPs.

However, money transmitters and bureaux de change are the highest risk businesses in terms of likelihood of being used by money launderers and the impact of failure to implement anti money laundering systems and policies. The main focus on identifying unregistered traders will be in these sectors.

There are a range of additional measures Compliance Officers can use to obtain evidence of relevant businesses trading unsupervised.

These include:

• asking principals with agents, who may carry out MSB activity in their own right in addition to acting as an agent, to check if these businesses have registered.
• When visiting MSBs check if any MSBs they do business with are registered.
• checking telephone directories, local newspapers and internet sites. This may provide initial evidence that a business is trading unsupervised.
• checking cancelled registrations to identify other MSBs they have dealt with. Contact can then be made with those MSBs to check whether the suspect business is continuing to act as an MSB, particularly in the case of money transmitters.
• This can be followed up by targeted spot checks consisting of a simple drive or walk past the suspect premises to see if there is any sign of business activity.
• Unannounced visits to businesses where there is a high risk that they are still carrying out MSB activity.

For further details about unannounced visits see MLR3C13000 

Some of these activities may constitute Directed Surveillance. Further guidance about this can be found in the Enforcement Handbook 

If there is any doubt then consent should be obtained before the commencement of any surveillance activity.