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KYC/AML requirements/process, first large client

Best practice for KYC/AML on boarding

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I'm an ICAEW CA with a consulting business, to date clients have been local and small, referred through local networks, ex colleagues etc and due to the nature of my engagements I don't have a large volume of clients.  Therefore to date KYC/AML has been relatively easy, straightforward and manual...taking copies of originals documents of Directors...passports, utility/council tax bills etc......check Companies House.....use the ICAEW free check service.  I have a simple tick box risk profile form I created myself and store the documents securely online.

I've been approached by an ex colleague to help lighten the load at a busy time of year at her company and do a few days for her.  This is great however the organisation is much larger than any previous clients.  There are 5 directors, not all in the UK and some are high profile individuals.  Therefore my normal AML/KYC process is a bit too basic.  What should I do?  What would be sufficient?

I've looked at services like Veriphy which work on a pay-as-you-go basis, would their £4 ID check for each director be sufficient.

The company is audited by KPMG, can I place any reliance on that?

Thanks, my question feels a bit perocial but I find the ICAEW guidance baffling at times!

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By Kaylee100
13th Jan 2021 22:15

Mercia offer a really good set of systems. Worth checking out.

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By Matrix
13th Jan 2021 23:16

What do you get free from the ICAEW?

I don’t have big clients but I id beneficial owners and not Directors.

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By paul.benny
14th Jan 2021 08:10

Although you don't set out the exact work you are doing, it sounds like you are acting as a contractor rather than this being a client for your firm in the more usual manner

On that basis, I don't think you need to do anything over and above your normal processes. That said, I would still document your reasoning and agree a statement of work. You might also want to expressly exclude certain work in your SoW.

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David Winch
By David Winch
14th Jan 2021 08:33

In terms of "reliance", you cannot simply assume someone else (KPMG in this case) must have done client due diligence. There has to be an agreement. See Reg 39 at
https://www.legislation.gov.uk/uksi/2017/692/regulation/39/made
David

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By ireallyshouldknowthisbut
14th Jan 2021 08:55

if this is all new for you, then speak to the ICAEW. They are really helpful for things like this.

Things like the Veriphy services are quite frankly a key part of any ID checks, no matter how small and local the client. Everyone is "local" to somewhere.

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