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AML - Firm to firm instructions

AML - Firm to firm instructions

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We are being engaged by another firm of accountants to undertake a defined piece of work for them where we have specialist expertise.

Is it necessary for us to undertake AML checks on them? We know (loosely) of the firm and can see their web site etc.

If it is necessary, what form should the AML checks take?

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By Old Greying Accountant
11th Nov 2013 14:38

I would think ...

... (probably wrongly) assuming you are dealing directly with another accountancy firm and won't be billing the client direct that you would need a sub-contractor agreement in place and that should incorporate details of their MLO and the procures etc they expect you to follow, so you know who to report to if you have any suspicions. In my humble view the MLR risk is with them not you.

If they are a regulated firm I do not see the need for you to do anything on them ML wise.

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By stepurhan
11th Nov 2013 15:04

Check your client not theirs

I would agree with OGA about not needing to check their client's identity necessarily, dependent on the agreement between you.

However, the accountancy firm is your client. You need to perform the money-laundering checks on them the same way as for any other client. In fact, since you will be in possession of information related to the ultimate end client, you probably need to do a robust check to ensure you can rely on their MLR procedures. The fact that you are not working for the end client is probably a defence regardless, but I'd want to be sure of my position.

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