HMRC has published the final version of guidance on the ‘fit and proper’ test it will carry out as part of the money laundering supervision registration process for money service businesses and trust or company service providers. The test relates to the suitability of the beneficial owners, officers and senior management of these businesses. Interim guidance was first published in June 2017.
The revised guidance includes clarification that money service businesses are responsible for ensuring that their agents are also fit and proper. Businesses may appoint agents to perform services such as taking money transmission instructions from customers, accepting cheques for encashment, or undertaking currency exchange.
In particular, principal businesses must take ‘effective steps’ to prevent individuals with convictions listed in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations, SI 2017/692, schedule 3 from becoming, or remaining, responsible persons at their agents. Such steps will include, but are not limited to, basic disclosure and barring service checks.
HMRC has published the final version of guidance on the ‘fit and proper’ test it will carry out as part of the money laundering supervision registration process for money service businesses and trust or company service providers. The test relates to the suitability of the beneficial owners, officers and senior management of these businesses. Interim guidance was first published in June 2017.
The revised guidance includes clarification that money service businesses are responsible for ensuring that their agents are also fit and proper. Businesses may appoint agents to perform services such as taking money transmission instructions from customers, accepting cheques for encashment, or undertaking currency exchange.
In particular, principal businesses must take ‘effective steps’ to prevent individuals with convictions listed in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations, SI 2017/692, schedule 3 from becoming, or remaining, responsible persons at their agents. Such steps will include, but are not limited to, basic disclosure and barring service checks.
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