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Doing work for a client's clients

I have been asked to review full statutory accounts and do forecasts for a client's clients

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I have been asked by a potential new client to review and analyse full statutory accounts and management accounts of their clients, to enable their clients to prepare forecasts. I am regulated by HMRC for AML, due to the other work I do for my other clients (accounts, payroll, tax returns etc).

(1) Is this type of work covered by AML? If not do I need to do ID checks etc on this new client?

(2) If it is covered by AML do I have any obligation re the end client or is that solely down to my client?


Many thanks


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25th Jan 2019 15:16

You've forgotten to mention what work your potential client does and whether it is an activity under which they have AML obligations on which you might rely.

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25th Jan 2019 15:18

You just have to ID your client, sfaIaa.

If the client's clients become your clients, that's a different matter.

As we say in the VAT business, "Who is supplying what to whom ?" ©

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26th Jan 2019 13:33

Effectively you are being requested to do accountancy work for your client's clients.
Your contract may be with your client, or with the client's client. You need to be clear which it is because of your contractual liabilities for negligence etc.
If your contract is with the client's client then he / she / it has become a client of yours and the usual AML rules apply.
If your contract is with your client then the client's client should be treated as a 'beneficial owner' on whose behalf the work is being done, so you need to ID them.
Of course you have the usual reporting obligations re any suspicions of money laundering (by anybody) which arise as a result of information received by you in the course of this work.
If your client is in the 'regulated sector' and has obtained ID of his clients already - and you seek to rely on that - then you need to comply with Reg 39 MLR 2017 in that respect.

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