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Payroll - Anti- Money Laundering

Payroll - Anti- Money Laundering

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Having recently taken over the practice i have worked in for the last 15 i have recently sent out new engagement letters to all of the clients, i have also aksed them to provide me with there passport numbers (for ID Checks) and to complete simple PEP questionaire, so that i can comply with AML

I have a client that i only provide Payroll services for, The company is based in the UK and is part of a European wide Group, they have recieved the pack and the contact i deal with, whom isn't a director, is complaning, One of the directors is based in Europe so i have asked for an Authorsied passport and utility bill

I believe i have to follow the procedures above in order to know whom i am working for.

Can someone please advise that the process i have gone through is correct, or is the process different if i am only providing payroll services?

Thanks in advance

 

 

Replies

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01st Dec 2018 11:49

I can only comment on experience. I used to work in payroll for RSM Tenon (and by extension, Baker Tilly after the takeover), and we never required the same ML ID for payroll than, for example, SA.

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By Matrix
01st Dec 2018 12:56

I wouldn't treat this client any differently but you would need to check the law and maybe with your AML provider and also see if there is anything already on file.

I expect you know that it is the beneficial owners, not the Directors, who you are required to identify.

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to Matrix
01st Dec 2018 13:32

Thanks for your Replies,

Matrix,
For the majority of my clients they are one and the same so I missed that in this case,

However, In this instance the Shares are held by the parent company, who are also listed as the "person of Significant control" due to shareholding, so i thought it best to ID the directors.

Should i have just checked the parent company?

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to ohorad44
01st Dec 2018 14:12

ohorad44 wrote:

However, In this instance the Shares are held by the parent company, who are also listed as the "person of Significant control" due to shareholding, so i thought it best to ID the directors.

Should i have just checked the parent company?

No expert but I believe that you carry on up the chain of control until you find the ultimate (real people) owners.
Similarly I don't believe that a company can be a PSC.
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By Matrix
to ohorad44
01st Dec 2018 14:14

You should absolutely identify the beneficial owners of the parent company unless you are able to get comfortable that this is not required for payroll services.

Were no AML checks done by your predecessor?

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to Matrix
01st Dec 2018 14:38

NO, and that is part of the reason why he is complaining,
I am also trading as a new company (the predecessors business was ran as a Sole trader), which is why i have issued engagement letters to everyone,

My predecessor was not great on sending those out either, and i have just received the pack of information back from the client "untouched and Unsigned" with a note stating "we have never filled in forms like this & as far as we are aware we are not required to"

I am reluctant to tell him i can't act as this is worth approx £6K a year in fees,

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to Matrix
01st Dec 2018 14:38

NO, and that is part of the reason why he is complaining,
I am also trading as a new company (the predecessors business was ran as a Sole trader), which is why i have issued engagement letters to everyone,

My predecessor was not great on sending those out either, and i have just received the pack of information back from the client "untouched and Unsigned" with a note stating "we have never filled in forms like this & as far as we are aware we are not required to"

I am reluctant to tell him i can't act as this is worth approx £6K a year in fees,

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