HMRC has published its Code of Practice for supervisory purposes for visits to businesses under Money Laundering Regulations (COP28). This Code of Practice tells you what you can expect from HMRC Supervisory staff and what they expect of you when they visit your business under the Money Laundering Regulations 2007.
The type of businesses that is required to register with HMRC under the Money Laundering Regulations and be supervised accordingly are;
- Money Service Businesses
- Trust or Company Service Providers
- Accountancy Service Providers
- High Value Dealers
The focus of the visit will be on your business’s risk sensitive anti-money laundering policies and procedures to make sure they successfully manage and reduce the money laundering and terrorist financing risks faced by your business.
During a visit HMRC supervisory staff we will always:
- check that the information held on the HMRC register is correct
- check that the right people within Money Service Businesses and Trust or Company Service Providers have undergone the fit and proper test
- ask you to explain how your risk sensitive anti-money laundering policies and procedures work
- answer any questions you have on your legal responsibilities under anti- money laundering legislation
- look at your risk assessment of the business’s customers, products and services
- look at the anti-money laundering policies, procedures and training you have implemented to manage and reduce the risks you have identified.
They may also:
- examine transaction records and related documents to check that the customer due diligence measures have been adequately applied
- evaluate your systems for identifying and reporting suspicious activity to the Serious Organised Crime Agency
- check that your staff are aware of the law relating to money laundering and terrorist financing and are sufficiently trained to recognise and deal with suspicious activity
- ensure you have adequate systems in place to manage your compliance with the Money Laundering Regulations 2007.
If you are a Money Service Business or High Value Dealer HMRC may inspect any cash found on the premises.
The full document can be downloaded in PDF format by clicking on the following link HMRC Guidance COP28
Visit the BTC website for compliance help and support for firms in the regulated sector.