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AML and clients who are non UK resident

AML and clients who are non UK resident

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Normally our procedures for AML checks are straight forward enough, but what procedures do you follow for "knowing your client" when they live outside of the UK, obviously we can ask for copy ID but what else do you do?

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16th Jul 2019 16:09

So, presumably you are unable to confirm their identity face-to-face?

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By NH
to dmitchell
16th Jul 2019 17:58

Correct, although that is nothing new as we have clients all over the UK, but at least with UK Residents we can do an AML search which shows up any issues

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to NH
17th Jul 2019 11:33

You could ask them to provide the original documents of their photographic ID via post, and follow this up with a Skype call (or the like) to confirm they are the person in the document.

Be mindful that if you can't personally verify their identity face-to-face, they are subject to enhanced due diligence requirements.

You may want to look into using a third party as part of the CDD process. This might be helpful:

https://www.grantthornton.ie/insights/blogs/third-party-reliance/

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17th Jul 2019 11:49

You may want to consider first and foremost if the client is low or high risk.

If low risk then certified ID & utility is enough.

It's the high-risk ones that you need to do enhanced due diligence.

Follow your/firm's client risk policies and AML procedures etc.

I have just had HMRC come and review my business.

HMRC does allow that if needed, you can start work for the client but then without unreasonable delay obtain the KYC/CDD documents.

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