AML and c/o address

What is the procedure?

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Dear Aweb community,

I am hoping David can clarify this for me please? Unless anyone else knows?

I have a client who is struggling financially and even though he works he can not afford a rent here in the town where we live. But at the same time he has to stay in this town because this is where the work is. As a result he is moving from sofa to sofa and he's just given me another c/o address. He was staying at his mum's before but now that he's staying at a friend's, I'm wondering how this works in terms of AML.

Is there something specific I need to do to ensure I have carrried out correct due diligence and compliance checks for AML purposes?

Thanks in advance to anyone who can provide some guidance.

Replies (15)

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By Roland195
08th Apr 2024 09:44

Where do his documents get sent - what address do HMRC, his bank etc have for him even if no paper statements are posted?

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Replying to Roland195:
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By Cylhia66
08th Apr 2024 10:46

Currently all his documents are being sent to his mum's and HMRC have his mum's address too.

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Replying to Cylhia66:
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By Roland195
08th Apr 2024 11:06

So isn't his mum's still his current, normal address with him just staying elsewhere while working?

Unless the nature of "staying with a friend" in more formal or permanent than the wording suggests, I'm not sure it changes anything except to raise the question why he is attempting to have his post sent c/o there? (from you anyway, doesn't seem fussed about his bank statements or HMRC bumf).

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Replying to Roland195:
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By Cylhia66
08th Apr 2024 11:26

What I meant is that he has now moved permanently to his friend's until something changes. He's given me his new c/o address because he knows I recommend letting HMRC know when he moves so that their letters don't get missed (he tends to receive a fair amount of letters from them for various reasons).

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Replying to Cylhia66:
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By Roland195
08th Apr 2024 11:37

So if he has moved permanently into his friend's house then it isn't really a care of address and what's the problem?

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By Cylhia66
08th Apr 2024 12:05

It's difficult to get the correct wording here. My apologies if what I am saying is not clear.
He is currently staying on his friend's sofa. I said permanent place but that's misleading. He's there for now but we don't know how long for and he has nowhere else to go at present. His friend wouldn't want my client to redirect all his mail there. HMRC is an exception because he really has to know if they write to him hence the use of c/o.

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Replying to Cylhia66:
DougScott
By Dougscott
08th Apr 2024 13:05

Why not care of you then if its just HMRC post?

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By Cylhia66
08th Apr 2024 13:19

oh god no! He has debt collectors on his back.

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By Roland195
08th Apr 2024 13:37

Assuming you were satisfied with the results of your AML procedures when you first engaged the client, I don't believe you have an immediate issue at the moment although I think updating the address with HMRC was not the best move (especially after seeing debt collectors might be turning up at his pal's door).

I'd think a note on your file explaining the temporary arrangements will be fine & satisfy the Gestapo but I think you would have to explain to your client about the damage this sort of thing will do to his credit record.

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Replying to Roland195:
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By Cylhia66
08th Apr 2024 13:52

Yes the AML results were in good order when we were first introduced.

It's a difficult one because if I had not updated his details with HMRC when he moved to his mum's his problems would have got worse. Now at least they can communicate about payment plans, debt recoveries and so on.

I will leave things as they are now then and just add a comment on my AML platform as you suggested.

Thank you for taking the time to talk to me about this and apologies I was struggling to explain the situation.

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DougScott
By Dougscott
08th Apr 2024 22:54

Just as a slight aside is it possible to be a UKtaxpayer if you have no fixed abode/address? And for someone like us to be their agent?

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By FactChecker
08th Apr 2024 23:39

Are you confusing 'UK taxpayer' with 'UK tax-resident' there?

You can certainly be the former simply by dint of getting paid via PAYE for a short-term employment where (as in many industry sectors) the employer doesn't really care about where you do or don't reside - so long as you are entitled to work in the UK (which is yet another set of definitions)!

Being their agent is a different kettle of fish ... which is really what OP was asking.

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Replying to Dougscott:
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By Paul Crowley
08th Apr 2024 23:53

If the initial AML stuff worked OK then I would just recommend that client used Mum as the HMRC and bank address. That address is stable and most mums love their sons.
Debt collectors and bailiffs have no power over mum.
Mum will not chuck post in the bin
All he needs to do is phone mum once a week. If he cannot be ars4d to do that, I would not act.

And I would never enter C/O on any address to anybody. All that says is THIS IS A FALSE ADDRESS.

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Replying to Dougscott:
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By Roland195
09th Apr 2024 09:49

This is an area that we have been warned about for sometime that online only verification and rigid AML is going to leave people, especially the vulnerable unable to access help or services.

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Replying to Roland195:
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By kim.shaw-and-co.com
17th Jun 2024 01:47

Roland195 wrote:

This is an area that we have been warned about for sometime that online only verification and rigid AML is going to leave people, especially the vulnerable unable to access help or services.

... and it will be getting worse. Mention is made of his own credit record, but his mum's address is at some risk generally and if he changes any of his other addresses to his pal's he puts theirs at risk too.

I rented a flat near work where the previous tenant had done a bunk back to India after being struck off the medical register following proceedings many years ago now and apart from the barrage of red reminders and angry demands that flooded the postbox there was initially damage to my own credit rating simply as a result of living at the same address she previously occupied.

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