I have been asked to do some bookkeeping for a local business, they already have an Accountant. In the course of discussion I advised them that I am governed by anti-money laundering legislation and would have to verify their identity etc.. but they came back to me on this, said they had already done this with their Accountant and refused. Please can you advise - providing bookkeeping services only, to a client with an Accountant, do I have to verify identity? I would have copies of their bank statements, the client has lived locally for a number of years and their business is based from home and the meeting took place there ... but the refusal to provide identity worries me. please could someone help me with the legislation on this one.
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Due diligence - reliance on third parties
This is what ANTI-MONEY LAUNDERING GUIDANCE FOR THE ACCOUNTANCY SECTOR says at para 5.33:- "Businesses may rely on third parties, subject to the third parties’ consent, to complete all or part of customer due diligence as set out below but they should be cautious in relying on third parties as they will remain liable for any failure to comply notwithstanding their reliance on a third party (See Regulation 17). Businesses should consider requiring copies of relevant information and documentation from the third parties, in order that they may satisfy themselves the information is sufficient."
@JWB
I am always wary of clients with that sort of attitude. If they are preventing you complying with your regulatory requirements, then will they expect you to ignore more regulatory requirements further down the line? A few minutes of their time can avoid a lot of your time being wasted by getting agreement from their accountants. Does this mean they are going to be unhelpful all the time?
Have you explained to them that this is a legal requirement, and that non-compliance is a very bad start to your relationship?
I know the checks are a nuisance, but clients usually comply ..... with a sigh, and a smile.
Internal bookkeeping
I would have thought that applied to employees, not self employed bookkeepers. I'm not 100% certain of that though. Are you going on payroll? I think that may exclude the need for MLR checks.
my two pennyworth
In my opinion you are an external bookkeeper and subject to the same regime as an accountant.
No question that this is under MLR
I don't have any problems in getting MLR documentation from new clients. I would see any prevarication as a red light to anyone being signed up.
I have been doing bookkeeping and management accounts either on or off clients' premises for years but consider all of them to be subject to the MLR.
Don't let them bully you. If you don't do the checks and and if you don't get the right paperwork then whoever's responsible for checking your MLR files may roast you slowly over the coals a few years hence.
If you don't like being an unpaid policeman you need to change profession.
Just a bookkeeper?
Ha ... that gives you an idea of the respect you could expect to receive from them!
Now get back under your rock, and don't speak unless spoken to! ;)