AML checks on EC (non-UK) citizens | AccountingWEB

AML checks on EC (non-UK) citizens

We have been approached to act for a UK limited company, the sole director and shareholder of which is Romanian. As he has not been in the UK long he will fail the usual residency and identity checks our AML search provider uses. We have a copy of his passport and Romanian ID card. Do these need to be authenticated or signed by a UK solicitor to pass muster for AML purposes?. This is quite urgent so any quick replies much appreciated.

davidwinch's picture

Have you seen the originals?    1 thanks

davidwinch | | Permalink

I am not clear whether you have seen the originals or simply been provided with photocopies.

If you have only been provided with photocopies then they should be authenticated by a solicitor (or other trustworthy person) who can confirm the copies correspond to the originals.

If you have seen the originals yourself (and made copies) that is sufficient.

I am assuming that you have met the individual face to face (and are happy that he is the passport holder), that there is nothing about his instructions to you which causes you to worry particularly about potential money laundering, and that he is not 'politically exposed' (e.g. a Romanian political leader or army general).

You may be able to check with your usual provider whether he is listed as a known terrorist etc.

I appreciate of course that the document he has presented to you as his passport may in fact be only his gym club membership document - and you would probably be none the wiser - but there is a limit to what you can do.

Obviously you will remain alert so if you see in future large transfers of monies or something else odd then you will consider carefully if a Suspicious Activity Report is required.


Thank you

RogerMT | | Permalink

Thank you David, your ongoing comments on this forum are always helpful and informative.

I have done the usual AML checks with our provider (Equifax), and the potential client is not a politically exposed person. We have seen him and his actual passport and ID card and both appear to genuine, and the photos bear a good likeness to him, and copies have been scanned, so all seems well.

Obviously we will be on the lookout for any suspicious activity through his company, and as it is likely we will be seeing his company's records once a quarter to prepare VAT Retuns a regular check can be maintained.

Thanks again.


The Black Knight | | Permalink

not having used AML providers...what do they actually confirm (just the identity from the electoral role ? etc ) or do they have access to previous criminal records (which would be of more relevance)

David do these providers that have sprung up to terrify us into payment really provide added value....when all the regs require is that you see some proof of identity ?

I usually take the line of least resistance...don't act if its too much trouble..

The safety must be in proving that you have seen the actual passport, (fake or otherwise).Who would in reality be able to tell the difference ? Very few people look like their passport photos's to me !!

Obviously you view him as high risk already ? taking an extra form of ID ? or do you still ask for belt and braces out of habit like we do ?

Added to which I note that companies house do not check identities, so you can almost create a new one there or at least file a smoke screen, but presumably HMRC would not set up a file if the person did not exist....or do they ?

How would any of these checks work if an identity had been stolen ? The banks regulary allow this to happen.. does this mean that their checks do not work ?



Mike Sturgess's picture

Electronic verification    1 thanks

Mike Sturgess | | Permalink

Most of these systems need your title, full name, address, date of birth, and home telephone number and check against a variety of databases, typically:

1) Electoral role - are you on the register (title, surname, first names, address)

2) Royal mail redirect - is there a diversion in place indicating you've moved

3) BT - Is there a telephone registered at that address to someone with your surname (good) and first initial (better)

4) Share database (used for details of credit cards, loans, mortgages) - does your name address and date of birth agree. N.B. they don't do a credit check or disclose balances etc, just that they know about you.

5) Mortality index - are you recorded as dead. I always find it reassuring when they confirm I'm not dead!

6) Births register - if you were born between 1984 to 2003 inclusive

7) Electricity supply - does that address have a current electricity supply? If you add the supplier code on the invoice it even checks that EDF or whoever is billing you at that address (avoids me putting a copy of your bill into photoshop and changing the address to a fictitious one)

8) PEP and Sanctions check - usually world wide

The system we use costs £3 per go for the standard check above, paid monthly in arrears with no commitment. A straight PEP / sanctions check costs £1.25 per go.

If you want you can run an enhanced check. This validates the passport and / or driving licence number. You can also validate a bank account this way.

Provided it is not high risk most people accept an electronic verification as adequate. For high risk, you need the additional proof that it's not someone else's information being presented. Typically this is done by sending your letter of erngagement to the home address or simply sending a form with the contact details to the home address with a stamped addressed reply envelpo and ask them to sign and confirm the details. Receipt of the reply confirms the ID.

Copy passports is cheaper, but sometimes more troublesome / embaressing, particularly for established clients. Given that the checks are instantaneous they also help where there are urgent deadlines. Many of our client firms of accountants use this as the primary method of ID checks.

3rd Parties & Isle of Man

paul s&w | | Permalink

What AML checks are required, if a UK accountancy practice is asked file a CT return and associated accounts on behalf another practice based in the Isle of Man?

The IOM firm has no provision for dealing with ixbrl accounts!

I am not sure whether the UK firm is acting on behalf of the company or the IOM firm.

Thank you in advance.



would tick the wrong box for me !

The Black Knight | | Permalink

Sounds like a lame reason to use your UK badge.......esp  when Isle of man..?

How much they paying ? LOL

Add comment
Log in or register to post comments
Group: Money laundering and crime
A group for discussing issues relating to suspected money laundering and other crime