Do I Need ID?

JodieR

I've got a client who I've worked for for about 3 years now doing bookkeeping, VAT & Payroll. They've got a chartered accountant who prepares management accounts and the final accounts etc. In Feb they got a huge investment and the 3 investors are also now company directors. I have never met these investors and can't see that I'll need to - please can someone confirm that I don't need to get all of their personal details and copies of ID for anti money laundering purposes?

Monsoon

Define huge. Do we know the money injected is legit? While we are probably sure it is, this is the kind of situation the MLR are designed for, as opposed to just checking Mrs Smith who runs the local greengrocers is actually Mrs Smith and not a member of Al Qaeda, selling bombs inside her bananas!

I would probably get ID to cover my butt and charge the client for it.

JodieR

well the chartered accountants were heavily involved in the investment 'deal' - they liased with the original directors, the lawyers who drew up the new share agreements and the investors themselves so I'm assuming that they have covered the AMLR side of things too - I just feel nosey asking now - I think i'm worried their reaction might be 'I've given all my details to the company who's drawing up the accounts, why should I give them to the girl who does the VAT returns?'

Rinske

I would personally still make sure you get them.

Technically anyone can tell you the chartered accountants are involved in this, but how much prove do you have?

I doubt they will mind it that much if you need the copy of the ID's now. I think the same would go for the bank and all kind of other people, so they should not be surprised with you asking about it.

Monsoon

The involvement of other professionals who also have AML responsibilities does not absolve a practitioner of complying with their own AML procedures.

However, remember AML is on a risk sensitive basis, i.e. it is not about "taking ID" but it is all about assessing risk. Therefore, if you decide that the involvement of banks and chartered accountants reduces the risk sufficiently, then you may decide ID isn't necessary, as long as you document your risk profile and your conclusions.

Personally, I would be taking ID in this case, simply because I need to ID each director of a company and if another one comes on board, I would expect to ID them as a matter of course. Unless anyone can point to any official guidance that says otherwise!

Monsoon

Also:

JodieR wrote: »

'I've given all my details to the company who's drawing up the accounts, why should I give them to the girl who does the VAT returns?'

Because she is a professional, and is acting professionally in complying with her legal obligations.

Anyway, as Rinkse says, it's no great hassle to produce ID. I'd just ask them :-)