Yes we have looked at the group as a whole and they fall below the threshold on 2 of the 3 counts. I have taken the advice given above and made a detailed note on file about our thought process and obviously will continue to monitor closely for any activity involving the subsidiaries. Thanks all for constructive advice.
Thanks. We will not be auditing, and the UK entities fall below the threshold for consolidation. Otherwise we would be compelled to dig deeper.
Will do a detailed file note. Thanks for your help.
Yes. The helpline suggested that unless we are acting on behalf of the subsidiaries a note on file is enough, as long as we are clear on source of funds. Their caveat was to remember the "risk based approach", which is often mentioned but never actually described in practical terms. My risk assessment was what made me ask in the first place.
Thought I would see what others in the trenches are actually doing.
I know its a case of locking the stable door, but we try to complete all MLR due diligence before starting work, or at the very least before taking any payment. Otherwise by returning the funds you have effectively cleaned them.
That is what I hoped
Thanks David, I agree that we have nothing useful to add, and therefore that would indeed be a reasonable excuse. Thanks for confirming my understanding of our obligation though. I will put a note on my files to that effect.
Can't really wait...
We are already live on several clients. Have drafted our own amendments.
Engagement letters software
We are always on the lookout for whats new and streamlines our process, but we found the CCH toolkit a little unwieldy and decided not to renew. A manual we bought recently from SWAT UK has all sorts of template documents attached and the engagement letters look more or less like the ones we spent hours compiling. I think its still a cut and paste job however you approach it.
Engagement letter software
We are reviewing what we do and have the same issues as you. The CCH Engagement Letter toolkit does what you want and is about £200 a year plus VAT, but I am researching alternatives. We are keen to make sure we keep up with institute guidelines for wording and clauses. However you do it, the whole process seems disproportionately time-consuming.
Does the online verification take away the need for certification? That's the bit that's not very client-friendly. I couldn't find your previous comments re legal issues. Is it relating to Data Protection? Bottom line: if you have (uncertificated) copies of photo id and utility bill AND you have run an international ID check on Veriphy, including PEP and Sanctions which comes back clear, is that enough verification?