AML/Quality Assurance Visit if not living in UK

anyone have any experience

Didn't find your answer?

Does anyone have any experience of a Practice Assurance visit where you (either sole practice or as the MLRO) do not live in the UK?

Have they for example insisted that you meet in person in the UK?  

Replies (23)

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David Winch
By David Winch
12th Jun 2024 07:45

You do not say who your AML supervisor is. Many AML 'visits' are actually 'desktop' visits which the supervisor conducts at his own desk based on documents and information supplied by email etc and, if necessary by 'meeting' online.
Should not be a problem.
Presumably you operate a business which is carried on in the UK (see Reg 8 MLR 2017).
David

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Replying to davidwinch:
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By johnthegood
12th Jun 2024 08:47

David thanks for your reply, I don't want to go into too much detail (I might send you a PM) but I am having a bit of a battle with the PB over this.

I have been operating this way for over 15 years and they have been fully aware of the situation but they have thrown their toys out of the pram when I questioned why they are insisting on an in person meeting in the UK when all our records are cloud based.

They even said the meeting could be at any neutral location as long as it was in the UK, so they would be happy for me to turn up somewhere with a laptop but not to access the same information remotely. Seems totally bizarre in this day and age.

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Replying to johnthegood:
David Winch
By David Winch
12th Jun 2024 08:53

Tell me more!

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Replying to johnthegood:
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By I'msorryIhaven'taclue
12th Jun 2024 09:00

johnthegood wrote:

They even said the meeting could be at any neutral location as long as it was in the UK,

Take them at their word and elect for The Isle of Wight!

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Replying to I'msorryIhaven'taclue:
paddle steamer
By DJKL
12th Jun 2024 09:36

Summit of Ben Nevis?

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Replying to I'msorryIhaven'taclue:
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By Paul Morton
14th Jun 2024 09:13

You can use my office, I'm on the Isle of Wight :)

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Replying to I'msorryIhaven'taclue:
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By Rgab1947
14th Jun 2024 09:25

There is a Scottish Island that is inhabited. Not sure on WiFi though.

Outer Hebrides could do as well. Apparently quiet pretty in summer.

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Replying to I'msorryIhaven'taclue:
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By Rgab1947
14th Jun 2024 09:28

Repeat sorry. Its Friday.

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By Tax Dragon
12th Jun 2024 09:40

Your (firm's) UK PE seems an obvious choice.

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DougScott
By Dougscott
12th Jun 2024 09:49

Presumably your registration is at a UK Address so it seems not unreasonable to ask for a face-to-face meeting in the jurisdiction in which your registration is. What's the big deal?

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Replying to Dougscott:
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By johnthegood
12th Jun 2024 09:58

Dougscott wrote:

Presumably your registration is at a UK Address so it seems not unreasonable to ask for a face-to-face meeting in the jurisdiction in which your registration is. What's the big deal?

Firstly it is actually a very big deal for me for reasons that I will not go into. If they insist I will have to of course.

But quite honestly with all the records being cloud based, and the fact that they are not even insisting that they need to visit the office, I am struggling to see why an in person meeting is required.

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Replying to johnthegood:
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By Paul Crowley
12th Jun 2024 10:13

Maybe they have not heard of zoom?

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Replying to johnthegood:
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By FactChecker
12th Jun 2024 14:43

"I am struggling to see why an in person meeting is required"

Not meaning to be alarmist but there's no possibility that they'll be waiting for you so as to clap on the handcuffs?
It's just that if you've really explored all the other permutations suggested ... I'm left with the feeling that the only thing none of those other options provides is your physical presence within a UK jurisdiction.

Which isn't an obvious part of the AMLR process ... or is it, David?

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By Tax Dragon
12th Jun 2024 10:43

Trying to be constructive, would they be satisfied if they met someone else at the PE and while they were there you met them over the airwaves? Or some similar arrangement.

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Replying to Tax Dragon:
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By johnthegood
12th Jun 2024 12:55

Tax Dragon wrote:

Trying to be constructive, would they be satisfied if they met someone else at the PE and while they were there you met them over the airwaves? Or some similar arrangement.

Given that they suggested I meet them at some other location of my choice or even at the PBs office, I don't think them being physically at the PE/Office is important to them.

As I say none of the data they need to see is there anyway - its 2024, its all on the cloud ya know!

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Replying to johnthegood:
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By Tax Dragon
12th Jun 2024 14:58

I see you answered the question on the PB's behalf.

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Stepurhan
By stepurhan
12th Jun 2024 10:45

I would be interested in the esteemed Mr Winch's take on this but, could it be because they want to be able to verify the MLRO that is being supervised?

Whilst difficult to do live, video can be faked. Maybe they perceive a non-UK MLRO for a UK-based practice as higher risk so they are wanting to undertake higher due diligence accordingly.

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Replying to stepurhan:
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By johnthegood
12th Jun 2024 12:53

stepurhan wrote:

I would be interested in the esteemed Mr Winch's take on this but, could it be because they want to be able to verify the MLRO that is being supervised?

Given that I have been a member of the PB for over 25 years, and have gone through various ID checks with them over that time I cant see that as a reason for it. anyway, whatever will be will be....I have been feeling for a long time now that the PBs are no longer there to help us and I would be better off supervised by HMRC

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Replying to johnthegood:
DougScott
By Dougscott
12th Jun 2024 13:14

Yes, I'm very glad not to have ever qualified and joined a PB. Looking from the outside in they seem more interested in extracting money from members than actually helping them.

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Replying to Dougscott:
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By Tax Dragon
12th Jun 2024 13:22

On the other hand, I know members who have received excellent counsel of various kinds from theirs, so it's not all take take take.

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Replying to Tax Dragon:
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By mail.taxperfect.co.uk
20th Jun 2024 12:39

Tax Dragon wrote:

On the other hand, I know members who have received excellent counsel of various kinds from theirs, so it's not all take take take.

Agreed. I have approached my PB on a few occasions for advice on AML matters and they have been very responsive and helpful.

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Replying to johnthegood:
Stepurhan
By stepurhan
12th Jun 2024 15:35

johnthegood wrote:

stepurhan wrote:

I would be interested in the esteemed Mr Winch's take on this but, could it be because they want to be able to verify the MLRO that is being supervised?

Given that I have been a member of the PB for over 25 years, and have gone through various ID checks with them over that time I cant see that as a reason for it.

Have you done any of those ID checks as the current firm and since you moved abroad?

Because the visit is not about verifying you are a genuine person. They are verifying that you (the actual person they have done ID checks on in the past) are really the MLRO of this UK firm. Can you not imagine a situation where an unscrupulous former colleague, knowing you are no longer in the UK, used your details for AML supervision? Such a person could assume that, since you are no longer in the country, the chances of you registering as a UK MLRO are slim so they don't risk getting caught out.

In other words, you seem to be moaning about the PB ensuring you are not a victim of identity theft.

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By mail.taxperfect.co.uk
20th Jun 2024 12:42

Have you asked then to come to you, or do they insist it has to be on UK soil? If they simply want to verify your identity in person then surely they can do that where you are based. Maybe it's to do with something which must be done on UK soil. Just surmising.

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