ECSH32630 - Visits to a business with a large number branches
Source: gov.uk (2025-02-05)


You may be allocated a case which involves arranging a number of branch visits. From your initial review of the Project Initiation Document (PID) (ECSH32705 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32705)) and the Standard Information Package (SIP) (ECSH32710 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32710)) you should be aware if your compliance check involves branch visits or whether you are required to arrange a number of branch visits to be carried out by other caseworkers.

During an intervention, you may also decide that branch visits are needed to address and test additional risks that you have identified. In these circumstances, you should discuss this with your Team Leader and, depending on resources, additional cases may be packaged.

Business structure

From your initial review, you should be aware of the following points:
- Whether the business is an HMRC Large Business (if so, as the lead officer, you should make contact with the Customer Compliance Manager (CCM)). If so, you must follow the guidance in ECSH32625 (https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh32625).
- Whether the business is part of a group and has a supervised parent, or any other sister companies supervised by HMRC.
- Whether the business is a franchisor or a franchisee.
- The number of branches.
Visit to the head office

Where you are the lead officer carrying out visits to a business with a large number of branches, you should make sure that the first visit is to the head office where you can:
- Confirm the business structure and operating model against information submitted as part of their application on ETMP. Please note, some business with a large number of premises may not be shown on ETMP and you will need to contact the Authorisations Large Trader team to obtain the information.
- Review all business activities and confirm those which are in scope for supervision, including activities supervised or regulated by another supervisory body (for example, the Financial Conduct Authority (FCA)).
- Identify key personnel and their roles and responsibilities.
- Confirm registered details, including the number of branches.
- Confirm that all beneficial owners, officer and managers (BOOMs) have passed the appropriate Fit and Proper or Approvals test - guidance on the fit and proper test on GOV.UK (https://www.gov.uk/guidance/money-laundering-regulations-apply-for-the-fit-and-proper-test).
- Discuss and record the business’s perceived risk of money laundering, terrorist and proliferation financing (ML/TF/PF), and specific products which are considered to carry a higher risk.
- Confirm customer due diligence (CDD) processes.
- Discuss record-keeping systems and access to reports for data analysis.
- Discuss staff who carry out relevant activities and how they are recruited and screened, particularly those with senior positions relating to the business’s compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).
- Discuss when and how training is provided, where training material is held and who is responsible for reviewing it and ensuring it is up to date.
It is important to confirm the number of branches match those registered. You can do this by asking for a list from the business and then reconcile the list against registered premises shown in ETMP.

It is important to establish where branch records are stored (for example, some may be purely digital and accessible at every office whereas some may be paper-based and only available at branches). This will help you to arrange branch visits where applicable. For example, where all records are available at the head office, you may not need to conduct additional branch visits.

A number of visits to head office may be needed to fully establish and understand all of the above.

Policies, controls and procedures covering a group structure or franchise

The same policies, controls and procedures (PCPs) may cover the whole of the group or franchise. It is important that you understand any deviation from the standard PCPs.

If you establish breaches of MLR 2017 which may span across the entire group, discuss this with your team leader and the Sector Specialist to establish whether further cases need to be packaged.

Planning branch visits

When planning visits to branches, you should consider:
- Who will be involved with the branch visits, you may need to consider the locations, the teams available and the experience of the officers.
- A time frame for the branch visits to be carried out.
- How the branch visits are being carried out, for example with or without prior appointment.
- What to do during the branch visits such as a cash inspection where applicable.
- What are the specific risks to test during the branch visits.
Advise the business that you intend to carry out visits to their branches. Do not inform head office which branches you intend to visit, although a timescale would be appropriate, for example in a particular month or between two specific dates. They may advise their branches of this. Provided head office agree to the branch visiting programme, visits carried out without a prior appointment are not deemed to be unannounced visits. Remind the business that all HMRC visiting officers will produce their HMRC identity card on arrival at the premises. If there is any doubt that the individual is an HMRC visiting officer, inform the business that there is guidance available on GOV.UK. (https://www.gov.uk/guidance/confirm-the-identity-of-someone-representing-hmrc#:~:text=Confirm%20a%20HMRC%20collector's%20identity,-A%20HMRC%20collector&text=Make%20a%20note%20of%20the%20name%20and%20serial%20number%20on,that%20the%20person%20represents%20HMRC.)

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Best practice points

As best practice, you should:
- Meet with the business’s senior management team before conducting the branch visits
- Fully review and consider the business’s anti-money laundering PCPs to inform testing
- Create briefings and templates / logs for additional compliance officers to complete (contact the Sector Specialists for examples) - additional support may also be needed (for example regular drop-ins/feedback sessions) keep Compliance Team Leaders updated as to resource allocation for branch visits.
- Analyse data as soon as possible to review your testing programme.
- Keep the business informed regarding progress.