ID check required for non-resident

ID check required for non-resident

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A client is intending to start a new UK company with two other shareholders/directors, one of whom is American, lives in the US and rarely comes to the UK. What do I need in terms of ID checks for money laundering purposes?
Nick

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By User deleted
13th Dec 2004 14:42

Thanks David
That's exactly what I needed to know.

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David Winch
By David Winch
11th Dec 2004 23:58

US director of UK company

Nick

This needs some thought! It is not the case that one needs identification for every director or every shareholder of a company client. So you may feel that getting ID from the UK directors is sufficient for your purposes.

On the other hand, you may feel that the US side is key to the company and your knowledge of it - and there is clearly a greater risk of money laundering if international trading and money movement is going on.

The decision is yours. It would be a good idea to keep a file note of your decision, the information on which it is based and your reasoning.

If you do feel the need to get ID from the US director then you could ask him to visit his attorney with his passport and have the attorney send you a certified copy of the passport and a letter confirming that the attorney has seen the director and the passport photo is a good likeness and that the attorney is satisfied that the ID of the director is authentic.

Ideally you should then confirm the existence of the US attorney by checking with his regulatory body.

Ultimately the question is: "Are you satisfied that you have adequate ID and 'know your client' information about the company (bearing in mind the activities of the company and the risks of money laundering)?"

AccountingWeb has produced a money laundering CD aimed at helping you understand this legislation and ensure your compliance - further details are available here.

If you are an MLRO you can get confidential one-to-one email support, information and NewsAlerts from my website www.mlrosupport.co.uk.

David
[email protected]

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