Online ID search for AML

Online ID search for AML

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A couple of Accountants subcontract some tax and accounts work to me. I do not particularly want to rely on their AML procedures – although they are members of professional bodies and properly registered. I was thinking of using AML search to obtain some ID assurance for myself. I gather I must inform the client that I am undertaking this search – is there an alternative method? Obviously the Accountants do not want clients to know job has been subbed to me. Am I being too cautious, should I just rely on their own ID checking and get a letter from them stating that they have performed all ID checks on clients passed to me to work on?

Thanks for any help given.

Nick

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By steveoneill
27th Jun 2008 10:07

Changes to POCA
Nick

Under the ML Regulations the obligation is your identify and verify your clients. In this instance, your clients are the accountancy firm you sub-contract to. Therefore your obligation is to verify them, not their clients.

One of the main problems thus has always posed was for the offence of “tipping off” when suspicion arises in the fact you could not inform the contracting firm of SAR’s you make or suspicion you have since this may be tipping off. However with amendments to POCA which came in April 08 you are now allowed to discuss these suspicions with other professionals involved in the same case, on the premise that two heads are better than one, unless of course you suspect involvement by the other professional.
In the light of these amendments this is going to be taken further, HMRC will announce in July that HMRC supervised subcontractors who exclusively subcontract to one or more other HMRC supervised accountancy firms can by written agreement become apart of the ML regime of the main contracting firm(s), therefore not requiring registration and supervision in their names.

We have yet to see if this could be extended in any way to the other 14 self regulatory professional bodies, since they of course, can only supervise their own members.

If the firms you contract to are Chartered or Chartered Certified accountants you are allowed under the ML Regs 2007 to rely upon them anyway for the CDD process as long as they give you permission. If they are members of other professional bodies they should not object to your cautiousness and help copy you in on any verification evidence. The whole idea is to let the professional work on cases together and not separately. It you did not trust the other firm, I doubt you would be doing business with them.

Steve O’Neill MICA (Dip.AML)
Business Tax Centre Ltd

for more information visit www.btc-nw.co.uk

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