Electronic AML - satisfactory?

Electronic AML

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We are thinking of using an electronic AML system.

Currently, for clients who we do not meet face to face, we ask for a certified copy of their proof of ID and proof of address. However, going forward (for efficiency reasons), we would like to do an electronic AML search.

Is this sufficient and acceptable for complying with Client Due Diligence?

Replies (9)

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By pauljohnston
17th Jun 2016 11:01

David Winch covered this point in a recent post. I hope someone will point you in the direction of the post. It appears that the amount of diligence is based on the risk profile of the client and what he/she wants you to do,

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Replying to pauljohnston:
David Winch
By David Winch
17th Jun 2016 11:04

pauljohnston wrote:

David Winch covered this point in a recent post. I hope someone will point you in the direction of the post. It appears that the amount of diligence is based on the risk profile of the client and what he/she wants you to do,


https://www.accountingweb.co.uk/any-answers/internet-printout-statements...
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David Winch
By David Winch
17th Jun 2016 11:01

I would normally suggest that along with an electronic AML search you should send BY POST an engagement letter to the client's address & receive a signed copy back. That at least demonstrates that the client has access to post sent to that address.
Also, of course, you need alternative procedures for cases in which the electronic search does not produce an acceptable result.
David

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By Caber Feidh
20th Jun 2016 02:22

David's advice in his link could be very helpful to a client who is trying to follow the pre-action protocol required before making a claim against a negligent professional. The professional has notified his insurer who has then instructed a solicitor. The solicitor has refused to correspond with my client unless he provides a copy of his passport that has been certified by a local solicitor.

My client is naturally unwilling to incur what appears to be an unjustified expense whose only purpose seems to be impeding his complaint. So I will suggest he tells the solicitor (a) to do an online check from Veriphy, Experian or Creditsafe and (b) to post a letter to my client's address which my client can then sign and return.

Does anyone think that the solicitor's requirement is justified? The (allegedly) negligent professional has visited the client at home and has extensive email and letter correspondence on his file.

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Replying to Caber Feidh:
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By pauljohnston
21st Jun 2016 07:39

In his post Caber Feidh mentioned certificatuion. I feel that the solicitor is paying lip service regarding AML. You may wish to know that the POst Office do a certification service http://www.postoffice.co.uk/document-certification-service which may be a half-way house.

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Replying to pauljohnston:
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By chatman
21st Jun 2016 09:05

That's a good tip, Paul. I have just had a look at the web page and it looks like you have to take your own photocopies. It got me wondering: how can they certify them as exact copies if they don't make the copies themselves?

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Replying to chatman:
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By pauljohnston
22nd Jun 2016 09:40

Hi Chatman. When I used this I had to take the original and the copy.

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Replying to pauljohnston:
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By chatman
22nd Jun 2016 10:59

Yes, that is what it says you have to do. It's mad isn't it!

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Replying to pauljohnston:
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By Caber Feidh
23rd Jun 2016 01:25

Thank you Paul for your link. With that and the earlier advice about Veriphy etc my client should be able to restrict the inconvenience caused by the obstructive solicitor. Accountingweb's helpers succeed again.

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