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AML and Know your client requirements

What is needed to meet AML and know your client requirements?

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Firstly I clarify that we do and have been carrying out know your client/anti money requirement procedures but we'd like some feedback on what other accountants in practice are doing please. We are not regulated Independent Financial Advisors also.

We take copies of original passport/ photographic driving licence (with address) and now use Creditsafe AML checks, which may replace the passport/driving licence copying, although copying the documents is not onerous. We have grown to liken the Creditsafe checks and they are usually quick to complete.

We also subscribe to Mercia's Practice Assurance Manual and their (lengthy) New Client Checklist (50 odd questions) and Existing Client Checklist. The Mercia New Client Checklist can take quite a bit of time to complete.

We really want to cut the work down to a sensible minimum and avoid as much unnecessary ticking and paperwork as possible, whilst still being completely compliant.

What do other accountants do and what system(s) do they use please?



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08th Jul 2019 15:02

Yet to be convinced by the point of Creditsafe etc particularly in the case here where you evidently meet clients face to face as routine and can easily view original documentation.

Never been a fan of checklists - the lengthier, the less likely attention is paid to any individual area however I would bet that that most are utterly irrelevant to your clients anyway.

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By Maslins
08th Jul 2019 15:56

I think a key purpose of the online checks that seeing passport etc doesn't cover is whether someone's on known terrorist/politically exposed person lists.

Agree with Roland re checklists.

Sounds like you're currently doing a bit more than we do. Haven't had an institute visit in a while, but they didn't have any issues with our AML side last time they came.

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to Maslins
10th Jul 2019 11:19

From what I understand, the PEP information listed by the credit referencing agencies which provide these checks are drawn from some fairly unreliable registers with a lack of meaningful detail. There also seems to confusion over what constitutes a PEP - Local Councillors are being included for example which was never the intention.

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09th Jul 2019 17:22
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09th Jul 2019 18:14

We tend (but not always) do the identity checks on TaxCalc, but that’s it. I found out the other day that we’re still asking for copies of ID, but it’s not my intention that we would.

I need to look into the extra bits & bobs. TaxCalc have a AML centre module, but it looks like a massive checklist that won’t ever get filled out.

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13th Jul 2019 18:10

I had a letter yesterday from HMRC AML and they want to see my client list and my procedure for AML. They are also going to phone me on the 5th August, a phone call that will take between 1 - 2 hours. What should I expect on this phone call. I am not registered with a professional body just HMRC and never had one of these checks before so appreciate what I should expect. I am a limited company and it is just myself and my husband. I meet all clients initially face to face and always obtain photo ID and proof of address details. Is this a standard check?

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to helen0904
16th Jul 2019 10:23

@helen0904 - the link that David put up is one I posted a few weeks ago - having had the same letter & phone call from HMRC AML Compliance Team. I am Ltd also & it's just me. I also am not registered with a prof body - I wonder if that's coincidence or a pattern?
However, following the 90 minute call - during which I was honest about what I do, don't do, laboured the point that I am a bookkeeper, I do not advise & all my clients have accountants who presumably have done all the AML checking & also check my work - I got a several page missive which was effectively a transcript of the conversation except the chap obviously wasn't too careful about his editing when he overtyped a previous copy as often my initials had changed & I was him not her!
I had no written procedures at all but what I do effectively constitutes some kind of risk assessment - now I have to write them up. I don't do ID checks but now have to start.
I was asked to confirm that it was a true reflection of the conversation so he could then send me the outcome - which could be a slap on the wrist, a notice to improve or a fine of £1500!
I admit that I haven't confirmed or replied yet- life & business has just got in the way - I intend to at some point but I have heard nothing more, not been chased to reply, nothing. Seems they have ticked their boxes & forgotten?

So, my advice, for what it's worth - I wanted to get snotty - 'I'm not the problem, go find someone who is!' but I resisted!, accept its a few hours of your time that you will never get back & agree to do what they want (within reason obviously) and don't worry about it.
All assuming, of course, that your client are not dodgy overseas 'businessmen' who have oodles of cash transactions & no paperwork & are not related to the Queen!
Hope that helps.

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16th Jul 2019 11:04

I use CreditSafe and find it reassuring, particularly for the clients that I know less well / new clients and particularly those who I may not meet in person. I did, I believe, get a reasonably good deal on the price though. I wouldn't have signed up for what they wanted to charge.
Do others just gather information on directors or on the actual company as well? I have come across both - insisting on address evidence for the company as well as for the directors but is that actually required?

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