Overseas Client AML Advice
I have been approached by a UK based individual who has a power of attorney of a relative that is based and lives overseas, this person has never lived in the UK but owns land in the UK. The UK based realtive wants to set up a partnership between the overseas individual and a local property developer to build some properties on this land and to sell them on.
I have been provided with the copy of the overseas individuals passport, the power of attorney and various correspondance letters from a firm of solicitors. What AML checks should i do? equifax et al would be no good.
My other concern is how would HMRC treat 64-8 and CWF1 being signed by a person other than than the one whose details are on the form. I'd like to see the look on the chaps face at longbenton when opens the 64-8/cwf1 envelope and finds the power of attorney in there! They would propbably just send it straight back to me without taking any action!
Many thanks for your comments,
Passport
Was the copy passport a CERTIFIED copy (i.e. was the copy signed by a solicitor or person of equivalent standing as being a true copy which had been compared against the original)?
If so you can accept the copy, but you need to check the existence of the solicitor etc who signed it. If an English solicitor look on the Law Society online database at
www.lawsociety.org.uk/choosingandusing/findasolicitor/view=solsearch.law
Presumably the power of attorney also gives the passport holder's name and address and this is also shown on the correspondence.
Since you are not meeting the passport holder Reg 14 MLR 2007 (enhanced due diligence) applies, but you should then have sufficient for his initial ID.
You also need to take the usual steps concerning the UK based individual who has approached you.
David