Is the Managing Agent my client?

Unsure of who the client is for AML

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Apologies for a possibly naïve query, but I'm having difficulty in determining who my client is defined as but, more importantly, to whom my resulting AML requirements relate. I am engaged by a Managing Agent (who deals with a number or residential management companies who are usually limited by guarantee of the leaseholders) to prepare S/C accounts. The M/A makes all payments on their behalf and invoices tenants for the service-charges to cover communal costs (that all pass through designated client bank accounts operated by the M/A). Information compiled by the M/A is then utilised to prepare the S/C statements which are then distributed (by the M/A) to the tenants and detail the charges collected and how they have been utilised.

Who is my client and to whom are all my AML responsibilities concerning KYC, CDD etc? The “directors” of the Management companies (which are technically dormant) are not bank signatories, and as “nominees” are largely in the same position as the other members, they often change, and exercise very limited control. Any constructive guidance or comments would be welcomed. (The M/A is not registered for AML supervision which is possibly another issue). 

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