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Outsourcing HMRC and Companies House Filing

What AML checks and Letter of Engagements do I need in place?

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I have been approached by a company that has asked if they can outsource their HMRC and Companies House filing to us. So they will be preparing the final TB, we would then take that TB prepare FRS accounts from them and send them back. They will then get the accounts finalised. This will be all completed under their name. We would have no contact with the client directly. I am happy we can provide these services, I am just a little considered what I will need in place in terms of letters of engagement and AML information.

Would I have to have a LoE with each of their clients or could I have one with just the company? Also, would I have to complete my own AML or can I rely on their AML procedures?

I have contacted HMRC and ACCA but they seem to take forever to answer, so any assistance would be much appreciated.

 

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Stepurhan
By stepurhan
05th Jan 2021 12:32

I would not touch this with a bargepole.

Why would you want your name associated with the filing of accounts and returns which may be complete works of fiction for all you know?

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By Wanderer
05th Jan 2021 12:39

What stepurhan said.

Would take me about 3 seconds to reject this approach.

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A Putey FACA
By Arthur Putey
05th Jan 2021 14:04

More detail on the proposed arrangement needed. Is your prospective client providing accounting/bookkeeping services to these companies? Is it an internal accounting function that wants someone to prepare the accounts without being the external accountant? Has the request come from offshore?

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Replying to Arthur Putey:
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By Beckett Taylor
05th Jan 2021 14:15

They are a UK company that is based very close to us. The provided bookkeeping services and other back-office services. They are not an internal accounting function.

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Replying to Beckett Taylor:
A Putey FACA
By Arthur Putey
05th Jan 2021 17:27

How do they frame their engagement with their clients? Are they members of a professional body and have a practising certificate, but just need the top slice of expertise to prepare the accounts? While I wholeheartedly agree with others who suggest that you would be unlikely to be able to prepare an FRS compliant set of accounts from just a TB, presumably this has already occurred to you and also to check the AML supervision of the company. You would only want to do this if you could ask questions (via your client) and demand to see relevant source documents and reconciliations. You'd be producing white label accounts (without your name on them), no harm in that on the face of it. However your PI provider might have a view. But provided the bookkeeping company stacks up, you are essentially sub-contracting, aren't you?

I'm just picking this example out of the air, but would it not be similar to signing up with cheapaccounting or a similar online offering that dishes out work to affiliated accountants?

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Replying to Arthur Putey:
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By Beckett Taylor
05th Jan 2021 17:36

Thank you for your reply. I would be getting all the information I needed to prepare the accounts, IE Bank statements, HP agreements, Debtors and creditors reports.

I think it would probably be best to engage the client directly, but be working with the middle man if you like.

As long as all of my engagement letters are signed, anti-money laundering risk assessments and know your client information is full filled I cant see much holding me back.

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Replying to Beckett Taylor:
A Putey FACA
By Arthur Putey
05th Jan 2021 18:10

Would that work for the bookkeeping company or are they trying to offer a one stop service to their customers? Had they been working with someone previously on that basis?

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David Winch
By David Winch
05th Jan 2021 14:14

Do have a look at Regulation 39 of the MLR 2017. There is a copy online at
https://www.legislation.gov.uk/uksi/2017/692/regulation/39/made
David

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By ireallyshouldknowthisbut
05th Jan 2021 14:15

Q: How can you prepare a set of accounts without understanding the business, speaking the client and seeing the transactional detail?

A: Very badly indeed.

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By Paul Crowley
05th Jan 2021 18:06

When David Winch replies
Take it seriously

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