Money Laundering Identification

Money Laundering Identification

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I have a potential company client based in Dubai with no links to UK or EU. The company registered in Dubai and the shareholders are Dubai nationals

I have received ID and signed passport copies of the shareholders however their utility bills (mobiles) are all PO box numbers in Dubai rather than physical addresses as the shareholder is very wealth with properties throughout Middle East and has every bill addressed to their PO box for convenience.

I understand that this is insufficient for ML purposes but the shareholder has no other utility bill etc at a home (non PO Box address).

What can I do? 

Thanks for help in advance

Replies (8)

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By johngroganjga
03rd May 2013 15:58

First step I suggest is to put ball in potential client's court and explain that you need documentary verification of his address and what does he suggest?

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By Roland195
03rd May 2013 16:28

How has it come to you?

Are we talking about a UK registered company?

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Replying to I'msorryIhaven'taclue:
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By jamieyoung
03rd May 2013 16:38

No registered in Dubai, has no UK company and no interests in UK.

I know them as an ex UK client has moved out to Dubai and works for them as one of the directors (I have all his ML docs and the others just not the beneficial owner).

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Replying to johngroganjga:
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By jamieyoung
03rd May 2013 16:54

work is bookkeeping and management accounts only. No regulatory reporting so yes definitely qualified

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David Winch
By David Winch
03rd May 2013 17:22

Have you performed CDD on the COMPANY? I would suggest that is your starting point.

If you are satisfied as to the ID of the company and its raison d'être and you understand its relationships with any other businesses operated by the beneficial owners of the company, then I would not stress unduly about the address of one beneficial owner (for whom you already have a certified copy of his passport).

As someone once said to me if a different context, "If anyone tells me I have to ask the Crown Prince for a copy of his electricity bill I shall tell them precisely where they can go look for it!".

David

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By jamieyoung
03rd May 2013 17:37

Hi David

yes have performed CDD and all seems very clear.

The rest of your comment is very reassuring as I was a bit worried that not having a utility bill in shareholders and beneficial owners name would mean I couldn't act - glad this is not the case.

 

Thanks

 

Jamie

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David Winch
By David Winch
03rd May 2013 18:18

OK
You are now in the happy position of knowing more about the Dubai equivalent of Companies House than I do!

Well done.

David

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By Roland195
06th May 2013 09:33

Out of interest

What does CDD on a company registered in the UAE amount to?

I would assume that you cannot just download from their equivalent of Companies House and even if you could, what exactly would it prove? I cannot see how you would have an idea of other connected businesses other than what you are told by the directors which seems to defeat the purpose.

Rather you than me. None of this makes any sense anymore.

 

 

 

 

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