Economic Crime Supervision Christening of HMRC AMLS
From 1st April 2021 HMRC Anti Money Laundering Supervision AMLS is renamed to Economic Crime Supervision (ECS).
1. What is AMLS and what are your obligations?
Money Service Businesses are obliged to:
- Report any suspicious activity to NCA
- To comply with MLR 2017
- Maintain KYC, comply with CDD and EDD
- Should define Risk Assessment policy
- Should have Anti-Money Laundering Policies and Procedures outlined
- Staff training and refresher trainings
Currency Exchange and Money Transfer businesses should:
- Identify Linked Transactions
- Identify PEP and Sanctioned individuals
2. How HMRC checks businesses registered for AMLS?
- HMRC may contact you to arrange a visit. This visit does not have a defined schedule and you may be contacted by HMRC at random.
- HMRC would like to talk to your MLRO who may be able to provide answers to the questions
- Professional advisers can be present at the time of this visit. We act as professional advisers and if you need us during your next HMRC visit contact us 02071939381 or email firstname.lastname@example.org
Records the officer will want to see:
- internal audits of how you’ve complied with internal anti-money laundering procedures and controls
- an external auditor’s report, if this covers your business’s compliance with the regulations
- relevant bank statements
- copies of and references to material proving a customer’s identity
- training records
- a job description of the senior manager in your business who is responsible for complying with anti-money laundering legislation
- records of suspicious transactions and of the action you took
- copies of any Suspicious Activity Reports (SARs) you submitted to the NCA, and any correspondence from the NCA concerning consent to proceed
At the end of the visit the officer will:
- review with you what they’ve done
- explain any areas of concern
- agree with you any action you need to take
- answer any questions you have
HMRC sent out an email on 30th March 2021 to all the registered businesses for its AML Supervision. The email looks something like below.