ECSH32615 - Face to Face visits
Source: gov.uk (2025-02-05)


Compliance interventions may be carried out face to face which enables you to see how a business operates and to talk to the relevant people in the business. This will help you to determine what information and level of checking is needed to establish the business’s compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).

Where you are conducting an announced visit, whereby you give prior notice of the visit to the business, you should follow the guidance for initial contact (ECSH32800 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32800)).

Sometimes it is necessary to carry out a visit without giving prior notice. You should follow the guidance for unannounced visits (ECSH32620 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32620)).

You must plan your visit to make effective use of your time on the business premises following (ECSH32900 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh33900)).

A visit will usually involve observing the carrying on of the business activities and an examination of business records (ECSH33700 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh33700)). You may also inspect the premises and any cash found on it, where appropriate to do so. These checks are usually carried out with the business’s consent, although you can use powers afforded by MLR 2017 - see ECSH (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh70000)70000 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh70000) for more details.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000) The Project Initiation Document (PID) in Caseflow will specify if your compliance check should be conducted by face-to-face visit (ECSH32705 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32705)).

A face to face visit may be considered appropriate for these compliance checks in the following circumstances:
- To see the business records and where they are normally kept.
- Where a business has failed to cooperate with attempts to complete the compliance check by correspondence.
- To carry out credibility checks.
- To speak to other staff members about their understanding of their anti-money laundering obligations.
This list is not exhaustive; whether a face to face visit is appropriate is determined by the risks. For more information regarding visits, please read information published on GOV.UK (https://www.gov.uk/guidance/money-laundering-regulations-business-inspections).

For guidance on arranging a visit, see ECSH32840 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32840).

If you intend to change the intervention approach set out in the PID, for example escalation of a DBI to a face-to-face visit or de-escalation of a face-to-face visit to a DBI, follow the guidance set out under the subheading “The intervention approach” in ECSH32600 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32600). Any divergence from the planned approach will require escalation through the senior officer and authorisation by the G7 Compliance Leads.