ECSH32820 - What to establish

You听should carry out the basic checks听referred to in the听颈苍颈迟颈补濒听谤别惫颈别飞 to understand what to听establish听when conducting your听initial听contact.听听

During the听initial听contact,听you听should听establish听and record the following information:听

  • Whether or not the business is a relevant person under听regulation 8 of听the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017). If not, a visit听isn鈥檛听needed听and the business needs to听deregister).听
  • Who听is responsible for听compliance with听MLR 2017听and the roles and responsibilities of staff.听This is听so that you can ensure that all relevant beneficial owners,听officers听and managers (BOOMs) have passed the appropriate听approval/fit听and Proper test and that you speak to the right people.
  • Who will be present during the compliance check: this could be the business owner, nominated officer, other听BOOMs and听members of staff听within the business, as well as any external advisors or legal representatives.听
  • Whether there is anything about their health or personal circumstances听that may make it difficult for them to deal with this check so that you can help (see ECSH32926).
  • What the business activities involve in order to gain听an听understanding 听of the business.
  • What the business model听is听(see听ECSH33120).听
  • Who the business鈥檚 clients or customers are.听
  • Where transaction or client records are held.听
  • Additional听information specific to the sectors听(see ECSH32825).听
  • Any听additional听information specified in the campaign听Project Information Document.
  • Whether the registration details听from ETMP听are correct and听up to date听(see听the operational guidance in听ECSH32731听and ECSH33100).
  • Whether听the business听is happy to communicate by email听(see听the operational guidance in听ECSH32812.
  • Whether the business has a current written risk assessment (RA) and policies, controls and procedures (PCP) document, and when these were last updated.
  • If the RA and PCP is stored digitally and how long it would take for the听business听to send it to you? You should consider听what would be听a reasonable听time frame听given听what you know about the business from your听颈苍颈迟颈补濒听谤别惫颈别飞 and initial contact,听ensuring that it is听appropriate.听听

There is further information听regarding听RA and PCP documents in听ECSH32825.