Money Laundering Regs & Non Face-to-Face Clients

SarahS

Hi

For those of you who have non face-to-face clients who may appoint you from far afield, like many online accounting firms these days, I'd be interested to hear what additional measures you take to verify the ID?

Thanks.

Sarah

T.C.

Just my question. What about the signing of a photo ID by a solicitor or similar person. Let's face it, a passport agency accepts this!!

whiterose

Cribbed mine from when I opened up a new online bank account recently.
I ask clients to verify their identity by providing one item from list 1, and one item from list 2 (they cannot be the same item). I ask for originals and take a copy and send the originals back.

List 1:
Unexpired passport
UK photo driving licence
HMRC coding/assessment/statement/tax credit
Notification of entitlement to state benefit/tax credit/state pension/student loan/other state or local authority grant.
Firearms certificate or shotgun licence

List 2:
Unexpired passport
UK photo driving licence
Council tax bill/demand
HMRC coding/assessment/statement/tax credit
Notification of entitlement to state benefit/tax credit/state pension/student loan/other state or local authority grant.
Firearms certificate or shotgun licence
Bank statement (not internet printed)
Utility bill (not more than three months old)

AK002

T.C. wrote: »

Just my question. What about the signing of a photo ID by a solicitor or similar person. Let's face it, a passport agency accepts this!!

This is allowable and would be my answer to the OPs question too.

deanshepherd

I doubt many clients would want to go and see a solicitor just to get a copy of their passport signed. If they don't want to send me their documents I just do a quick search on Veriphy.co.uk.

burg

Good website dean

Cheers

lorraine

List 1:
"HMRC coding/assessment/statement/tax credit"

Reading this I'm thinking would it be ok to accept a P60, as this would have the clients tax code and ni no. Do you think this would be acceptable???????

Julia Crouch

Hi Sarah

The situation that you have here would require you to carry out enhanced customer due diligence on the new clients not attending your practice.

The AAT has produced two documents available through the MIP pages on this website that you may find helpful and they specifically cover the question asked:

"Quick guide to anti money laundering legislation"

and

"Guidance on anti money laundering legislation"

Julia

Monsoon

What we do is take a copy of:

Photo ID (driving licence, passport, shotgun licence)
Recent (3 months) proof of address

Run electronic ID check (via amlsearch or business tax centre etc) for approx £5+VAT

Dont pay for Ltd Co ID checks - checking them on Co House and paying £1 to download latest 363a to check against the individual details you have is plenty.

MLR is on a risk sensitive basis. For the majority of clients, the above should be enough.