We are registered with HMRC AML, we ask all new clients for directors' passport or driving license and Know Your Client form of the director's personal details.
We then use these details to carry out an online AML check which tells you if it passes or fails.
My questions are;
1. How often should we carry out the AML check, the majority of our client's details don't change and we carry out payroll work including making BACs payments for some clients. My understanding is we should carry them out every three years.
2. We have recent international clients, we ask for a copy of the director's ID and carry out an international ID check but not an AML check, is this enough or do we need to ask for a hard copy of the director's address?
3. We recently have had a number of embassies asking for payroll services for their UK employees, how would we satisfy AML checks as there is no company/owner? Would a senior official suffice?
Thanks in advance