Client identification

Client identification

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I prepare the accounts for a flat management company and provide an accountant's report to the directors who are appointed by the tenants.
The bookkeeping and administration is done by a firm of surveyors who manage a number of developments.
When I was appointed it was by directors who were existing clients of mine with other hats on so I knew who they were.
Now there has been a wholesale change of directors so that I have briefly met one of them but have no identification for any of them.
The surveyors, while admitting that my client "may" be the management company, refuse to acknowledge that I need to identify the new directors, and won't put me in touch. They also tell me that I am "misinterpreting" the ICAEW helpsheet which I have shown them.

Any comments?

Tony Ball

Anthony Ball

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David Winch
By David Winch
05th Dec 2007 10:41

What is the money laundering risk?

Tony

What a strange situation!

Quite apart from money laundering regulation, I would not think you should prepare accounts for a company without knowing who its directors are and having some contact with them.

However, let's think about how you might satisfy your MLR obligations (to enable you to get on with the job) with a minimum of grief, expense and delay.

Of course you can (and should) do a search at Companies House to confirm the existence of the company and its registered office address. That is free. For £1 you can also get online from Companies House a "current appointments report" which will give you the names and addresses of the directors and their dates of birth.

If you wish you can do an online electronic check of a couple of the directors as individuals (cost from £4 per director) but you should inform the directors that you have carried out an electronic confirmation of their identity.

You may also wish to send an engagement letter to the company's registered office, if you have not previously done so.

All of that should satisfy your confirmation of ID requirements in relation to the money laundering regulations, bearing in mind this would appear to be a very low risk assignment (from an ML perspective) in view of the number and value of transactions. As you say that you have met one of the directors this client would not seem to come within the enhanced due diligence category of Regulation 14(2) MLR 2007.

However it sounds like the surveyors are being a pain! Presumably they wish to protect the directors from hassle.

David
www.MLROsupport.co.uk

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By AnonymousUser
05th Dec 2007 10:56

checking individuals' identity
Where is the best place to check online, in a fully compliant manner, the identity of individuals ?

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David Winch
By David Winch
05th Dec 2007 11:55

Online checks

James

I am not completely unbiased on this one as AML Search let me use their facilities for free. (I wonder why?!)

Their website is www.amlsearch.co.uk. They even have a little picture of me on their home page - ah bless!

David
www.MLROsupport.co.uk

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By Blakeney
06th Dec 2007 09:26

Thanks for the help
Thanks to David. It's put my mind at rest somewhat. I have acted for the company for three years and have all the checks in place. It was the complete change of directors that concerned me (and I was also a bit annoyed that non accountants should be telling me how to run my business). One of the new directors is, I find, well known locally so collateral evidence is easy to come by and I can contact him direct.

Tony Ball

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