Money Laundering Regulations (Due Diligence)

Client Due Diligence Checklist

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Hi All,

I put together a Limited Company Due Diligence Checklist (draft) to comply with MLR. I am not sure if I missed something or put some irrelevant items in, can someone help please?

  1. Client Questionaire (company name, reg nr, the law to which Company is subject, contact nr, address, etc ) signed by the client on behalf of the Compnay
  2. Certificate of Incorporation
  3. Memorandum of Association
  4. Articles or Association
  5. Proof of Registered Address 
  6. Proof of Principal Place of Business (if different to 5)
  7. Filed Audited Accounts (if available)
  8. Details of current company officers (i.e. directors, company secretary, the names of the board of directors or members of management body and senior management)
  9. Identity evidence for a) the individual dealing with the transaction and b) all other individuals or entities with 25% or more of the shares or voting rights in the company (see proof of identity checklist for individuals below)
  • Proof of Name (Passport, Birth Certificate, Driving Licence etc)
  • Proof of Address (Utility Bills, Council Tax Bill, Bank Statement etc)

Many thanks

 

Replies (1)

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David Winch
By David Winch
23rd May 2017 10:08

If you are currently reviewing your money laundering compliance I would suggest you consider the published draft of the 2017 Regulations - which are due to come into force next month. We do not yet have the final wording and the final version will need to be put before parliament (which obviously cannot happen until parliament reassembles after the election).

The draft is at
https://www.gov.uk/government/uploads/system/uploads/attachment_data/fil...

Consider particularly (in the context of your AML obligations) draft regs 18, 19, 21 (but note 21(6)), 24, 26, 27, 28, 30, 31, 33, 35, 36, 38, 39.

Obviously other regs may be relevant to advising clients and to your own obligations if you operate via a limited company etc.
David

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