AML - Keeping records | AccountingWEB

AML - Keeping records

I have a reasonable idea of what ID etc i need to obtain on clients to prove their identity and address, but what i am unsure of is what i should be doing with the proof after I have obtained it.

At the moment I photocopy the passport & proof of address and certify the copies as true copies of the original, i then complete a risk checklist to satisfy our AML policy and keep the copies with that checklist after a senior partner has signed it off to accept the client.

I thought we needed to keep the copies to prove we had completed the checks but one new client questioned the fact that her bank just looked at her ID and gave it back to her so why did we need to copy it - can anyone help me out? I don't want to fall foul of Data protection just because i am being over zealous with my AML record keeping!

cymraeg_draig's picture


cymraeg_draig | | Permalink

You need to keep copies as proof that you have indeed seen it. It's really for your own protection.

We keep copies, update them occasionally.  We dont keep paper copies, just scan them into a "client's ID" folder.


Malcolm McFarlin's picture

Risk assessment

Malcolm McFarlin | | Permalink

We keep copies of copy passport, home utility bill, HMRC docs such as VAT registration certificate, PAYE reference number in a separate file together with a risk assessment.

The most important thing you should do and it sounds like you already do] is to complete a risk assessment on each client.  HMRC will accept you do not have unlimited resources to undertake AML checks and as long as you have inspected the documents and verified them to some extent such as ensuring the passport is in date and bears a resemblance to the director then you should have no concerns.

Malcolm McFarlin


mlr & risk assessment

david5541 | | Permalink

i was recently on the other end as a prospective client looking for an adviser on overseas and trust aspects as I am likely to be responsible for the administration of millions of pounds of funds arriving here from the USA.

I approached a top 20(50?) firm kingston smith who after i completed a questionaire refused to act having already seen my pass port and utility bills beause of my risk profile.

MLR is a real hindrance to new business as far as i can see in this example, I wasnt even invited to meet them!

AMLCC - a complete solution

amlcc | | Permalink


Hi Kelvin


We have an anti-money laundering product which contains easy to use online risk assessments.

Our AMLCC product also includes:

  • Tailored hard copy compliance manual including template forms and written procedures statement
  • Online training modules (includes tests) for the Money Laundering Reporting Officer (MLRO) and staff
  • Online UNLIMITED risk assessment wizards to determine the level of risk each client poses
  • Online compliant client verification software to verify personal clients - cost from £3 plus VAT
  • Secure online records storage for risk assessments, verifications, training and internal reports
  • Reporting function to allow staff to submit internal reports to the MLRO
  • Monthly 'Compliance Matters' email keeping subscribers up to date on money laundering related matters 

The basis subscription costs £197 plus VAT and this gets you the hard copy compliance manual and four logins to the online site. Additional logins are available at £15 plus VAT each.

You can add as many clients as you wish on our system, there is no additional charge. 

We work with a number of Supervisory Bodies who recommend our product to their members.

We have testimonials to support the fact that our product has helped our subscribers get through their compliance visits (available on request). 

We offer an online demo over the phone which takes approx. 20 minutes. 

Please contact me for further information. 

Stephen Watts

01455 555468

[email protected]  


A delicate matter

Stephen Morris | | Permalink

What does one do with client stool samples? Might it not be an 'elf and safety issue if stored in the fridge alongside the milk?

Money well spent

garrycarter | | Permalink

If you haven't yet got all your MLR compliance ducks in a row, the aforementioned manual does seem a good buy - and I would suggest you invest sooner rather than later as HMRC and SOCA are getting tough on practices that have ignored the MLR on risk assessment and due diligence.

However, on the basis that 'other manuals are available' as the BBC would say, if you were to join the Institute of Certified Bookkeepers (ICB) you would get a free hard copy manual with all the relevant forms and instructions.  As from this month you can also do everything on-line and store securely.  Cost varies based on the level of membership you achieve but around £175.00 per annum.  This also includes a free MLR telephone advice line.

A good set of MLR records is your 'get out of jail' card when something nasty hits the fan.  The main thing to remember is that you should 'know your client' (KYC).  The less you know about your client, or the more you dislike about what they do, the higher the risk.  And it is very important to know who the beneficial owner of the business is.  It is often not the front man/woman with whom you are dealing.


Good luck.


Anti Money Laundering Compliance Plus

chatman | | Permalink

Anti Money Laundering Compliance Plus looks good too. I think it is about £95pa with a free evaluation copy.

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