AML - Looking for cheap, quick and dirty way to comply

AML - Looking for cheap, quick and dirty way to...

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I am progressing through with systemisation of my practice.  I had to pause and think about AML checks. I do not do any checks at the moment (horror?).

I would be greateful for any suggestions, to make this cheap, painless and quick. It really is no return type of work. Just do not want to do this but has to be done.

It will be for new clients only. Existing client I know by now, so should be okay. 

How about taking a copy of passport and utiliy bill? This should be okay?

Anyone like me- not done anything on AML? 

Replies (11)

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David Winch
By David Winch
30th Oct 2011 12:59

Passport

If you have a client whom you assess as low risk from an AML point of view (probably the bulk of your clients if you meet them face-to-face) then a passport is sufficient to ID them.

Don't forget if you are acting for a client which is not an individual (e.g. a company) you need to ID the client (as well as the individual(s) behind the client).  A quick check at Companies House will help there.

The MLR 2007 do require you to ID all clients - including existing ones.  In practice you may have sufficient copy documents on file to ID those clients, but you ought to indicate somewhere that you have done the ID and (preferably) have copies with that of the documents on which you have relied.

I understand you employ one member of staff.  No doubt you are your firm's MLRO.  The MLR 2007 require that yourself and your staff are adequately trained in AML matters (which can be done online).  The point is that you know what has to be done in terms of ID and in terms of reporting suspicions.

The MLR 2007 also require that you have AML procedures in place.  You might like to take a look HERE at a method of preparing a set of procedures that actually fit with what you do (rather than sit on a bookshelf being ignored until you get a monitoring visit!).

It all sounds more onerous than it is.

Good luck

David

www.MLROsupport.co.uk

Thanks (3)
By ShirleyM
30th Oct 2011 13:35

Cutting corners?

MLR checks (and engagement letters) should be an automatic part of your sign up procedures, and aren't difficult to do. If you really don't have time, or dislike the hassle, then you can do electronic checks and they only cost a few £. You should also be doing risk assessments.

What would you do if your MLR supervisory body checked your procedures? We have had a check (and passed with flying colours), so you will probably get a check at some point! 

Thanks (3)
FT
By FirstTab
30th Oct 2011 13:36

Agree

Thanks David and Shirley. I agree with what you say.

At growth (still there) stage some areas tend to be neglected. The one plus side of systemisation is it really made me think. I have a long way to go complete all systemisation.

I will make sure I put in place (and follow) procedures that comply with MLR. David you response is a big help here.

 

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Universe
By SteveOH
30th Oct 2011 13:52

Electronic verification

As ShirleyM said, you could try online verification. I use AML Search and they only charge £5 + Vat per search. It's great if the new client forgets to bring his passport or whatever. You key in the details and you have an answer in about 15 seconds. You can even do it while the client is sitting in front of you.

As you are a great fan at systemising your procedures, I can also recommend AML Compliance Plus. It's an online compliance system which ensures that everything you need to do as regards AML compliance is done. I use it and am a great fan. Their prices start at £95 for up to 30 clients, then £195 for up to 100 clients and so on.

Thanks (3)
FT
By FirstTab
30th Oct 2011 16:44

Steve OH

Thanks the link you gave are helpful. It will make things so much easier.

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By User deleted
30th Oct 2011 16:55

Electronic checks

I've used Veriphy to do electronic checks and this will be my standard method given I'm working towards never meeting my clients :) I went through all my clients and did them like that in one batch ages ago (years not months) working on the basis that although I had different appropriate bits for most of them on file it would make sense to have the same method for all & up to date. Ongoing it's part of my new client procedures & part of my annual check to confirm it doesn't need updating. It doesn't exactly take long or cost much and miles easier than getting a public flogging if you get caught without!

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By Roland195
31st Oct 2011 09:50

Electronic checks

I am not a fan of these - they are basically re-packaged credit checks which I was uncomfortable about using as I never got a satisfactory response as to if I needed express permission & what the consequences could be for my clients credit files.

In the time I did use them, I can't say I ever seen the point - you need a drivers licence/passport as a starting point anyway.

 

  

 

 

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Replying to User deleted:
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By User deleted
02nd Nov 2011 10:22

All you need ...

Roland195 wrote:

I am not a fan of these - they are basically re-packaged credit checks which I was uncomfortable about using as I never got a satisfactory response as to if I needed express permission & what the consequences could be for my clients credit files.

In the time I did use them, I can't say I ever seen the point - you need a drivers licence/passport as a starting point anyway.

 

Is to inform the client you are doing an electronic check, I do this at the meeting and in my engagement letter.

My understanding is that it makes a "soft" footprint on their credit file, which I explain to them. This means it just shows someone has done an AML check, not a credit check and has no impact on their rating.

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Replying to User deleted:
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By Roland195
03rd Nov 2011 09:58

I hope this is the case

Old Greying Accountant wrote:

Is to inform the client you are doing an electronic check, I do this at the meeting and in my engagement letter.

My understanding is that it makes a "soft" footprint on their credit file, which I explain to them. This means it just shows someone has done an AML check, not a credit check and has no impact on their rating.

I had been using the service for sometime when I happended to be out in the car listening to the radio and heard some "expert" on credit ratings explaining their arcane art. This lad said that everytime a credit file is accessed it leaves a "footprint" which can sometimes have negative consequences if for instance there are a few of these "footprints" appearing at the same time.

As I said, I never got a satisfactory answer from the provider and so felt uncomfortable using it even with their permission as I did not feel able to explain the process.

 

 

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By chatman
02nd Nov 2011 00:03

AML Compliance Plus

Another vote for AML Compliance Plus. it takes you through everything step by step, give you  reminders etc. Means you don't have to learn anything.

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By User deleted
03rd Nov 2011 10:23

As far i am aware ...

... the foot prints are distinguishable between those seeking credit and those confirming identity.

It is a surfeit of the former will have an adverse effect.

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