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Do MLR ID Checks apply if services are donated??

I am sole director of a small bookkeeping/accountancy business (limited Co) and wish to know if I donate my services to a charitable venture ( a company limited by guarantee currently seeking charitable status) do I still need to obtain all the ID checks and comply with the Money Laundering Regulations.




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In the course of business

The Money Laundering Regulations 2007 apply to an "external accountant" when "acting in the course of business carried on by them in the United Kingdom".

So if some of the work done by you in the course of your accountancy business is done without charge then, in my view at least, the MLR apply to that work just as much as any other.

Put it another way, suppose it turned out that someone was defrauding the charity (or to be soon, charity) company and you had failed to spot it.  Would you expect your professional indemnity insurers to refuse cover because the work was not done in the course of business?


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Many Thanks David

At least I know where I stand now.

- Brian

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Sorry David, just one more thing....

As well as checks on the actual company, as the company is limited by guarantee there are no shareholders, does this mean I need ID checks on all the directors.

Apologies if its a rudimental question but I haven't come across companies limited by guarantee before.


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Who is in control

The way I would look at this is that there are likely to be no individuals (or companies) who meet the criteria to be a 'beneficial owner' in terms of shareholdings (i.e. more than 25%) but there probably are a couple of people who 'run' things as far as finances are concerned.  They might be what in other circumstances might be known as the Chief Executive Officer / Managing Director and the Finance Director.  In this case they might be known as the Chairman and the Treasurer, or something along those lines.  In effect the key people you deal with.

I would ID them as individuals - but I would not feel it necessary or appropriate to ID all the directors (unless for some reason you think this is a particularly high risk client from a money laundering point of view - unlikely I expect!).


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Thanks Again David .......

......... Thanks very helpful



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