Is this really what we have to do for money laundering!?
I have just been told by my MLRO that before we do any work for an existing client, for whom we already hold ID - having got it when we took them on (anywhere from last week to the start of MLR), we have to get new ID.
As if it isnt bad enough trying to get accounts done and invoiced, this could cause considerable confusion and delay.
Surely if we have an existing (current) photo ID and we have 64-8 in place (so we can check ID at HMRC). The only thing we have to do is get the photo ID up to date - or do we even need to do that.
If we do have to get the new ID when does "new work" start from 1st January, 2011 SAITR, annual accounts, next phone call or even each phone call?
(The perceptive among you may notice that the previous paragraph is little more than a rant, but realistically when does it have to be updated?)