Money Laundering Regulations - The Book-keepers Forum (UK)

CGA Bookkeeping Services · Veteran Member

Money Laundering Regulations

Peasie · Expert

I was reading about a couple of these recently. I think it was costing about £4 or £5. (Maybe we are talking about different thngs). Doesn't apply to me just now but will in a few months when I start my business. I even thought about doing a check on myself but I think at the time I was put off because the website providing the service insisted I (as person doing the checking) had to be registered under the data protection act.

CGA Bookkeeping Services · Veteran Member

Hi Peasie

I managed to talk a company down to around £3 per report recently; but as this would have entailed advance purchasing of about 200 reports I decided to save my money and do it the old fashioned way!

But I think it would be sensible to invest in at some point as it would no doubt save considerable time.

Peasie · Expert

How much of your own time does it take the old fashioned way?
Would it be wiser to use one of these services if it is going to save you the time involved? Also is it not a bit of hassle asking people to provide these things?

EDIT : Maybe if I read your reply properly I wouldn't need to ask one of these questions. Someone recently mentioned on this forum there are no stupid questions - I think I have just proved them wrong.

-- Edited by Peasie on Monday 12th of July 2010 10:32:07 PM

kjmcculloch · Guru

I would be interested in this. It would certainly make it easier for checking out new clients. I did think it would be more expensive than the prices shown here. Can anyone point me in the direction of one of these companies?

Kris

CGA Bookkeeping Services · Veteran Member

Yes it can be quite time consuming especially with some clients who require chasing!

I forget which company I spoke with but I will try and locate the details..I wanted to confirm that the reports they provided were sufficient under Money Laundering Regulations - they claimed they were - but then I had the impression they would have told me anything provided I agreed to sign up!

semsley · Guru

I expect they are similiar to the on-line CRB services, we use one and we have to pay for 10 up-front, the system is torturous, we have to upload photographs, scans of documents, then the person applying has to be given a log in, password and their favourite colour so that they can confirm their DoB, address etc. It's far easier to do a paper one and just check the documents.

CGA Bookkeeping Services · Veteran Member

The system for the firm I looked at was to login type the name and address of the individual at which point checks were carried out on them for the address and electoral roll at that same address, I think there were five checks in all which generated a percentage. If this percentage was then above a certain threshold no further checks were required - nothing was stated as being required from the client.

I was going to check this with the ACCA and ensure that this was compliant with their guidelines, but I haven't quiite got round to that yet!

BackOfficeGroup · Guru

Not sure how good it is, but taxcalc.com do a package, they call it a search and verify and is not too expensive....

P

Peasie · Expert

BackOfficeGroup wrote:

Not sure how good it is, but taxcalc.com do a package, they call it a search and verify and is not too expensive....

P

That's similar to the one I saw. Requires a minimum payment of 15 searches (£75) - not unreasonable. Also requires you to be registered for Data Protection.

BackOfficeGroup · Guru

ah, yes, thats no good then. I'm still confused over this Data Protection stuff as we deal in payroll and hold all the personal data on our systems, so would have thought that should be covered......

P

Barkers · Veteran Member

Another stupid question here - so using these facilities prevents you having to request copies of ID from your client? Just out of curiosity, what else do you guys do to confirm/check your client apart from checking ID?

P.S - I registered with the ICO as i thought i had to with processing personal information - how come you guys aren't?

-- Edited by Barkers on Tuesday 13th of July 2010 08:57:32 PM

Amy8n · Veteran Member

BackOfficeGroup wrote:

Not sure how good it is, but taxcalc.com do a package, they call it a search and verify and is not too expensive....

P

I use Search & Verify by Taxcalc it find it excellent as it saves so much time and hassle. It's especially ideal for clients who you need to start working for straight away as well as ones based further afield.

I'm also registered under the data protection act because the outcome from last years ICB seminars suggested that we should be if we analyse data.

Amy8n · Veteran Member

Just to add, you do need to get permission from the client to carry out an online check but I have a paragraph in my letter of engagement which states I need to carry out an identification check and by signing the letter they agree to it.

BackOfficeGroup · Guru

Barkers

You still need to get the ID from your client, expecially photo ID, as they may not be who they say they are and the online checks is just an enhanced check!

Amy

Good to know. I would register under Data protection, its only £35 and makes you look more professional, IMHO

P

kjmcculloch · Guru

Philip,

Still needing to get photo ID.... I can see where you're coming from, however I recently sold a house and used a solicitor some distance from me. I never actually had to meet them or send them any personal ID, they did all the checks online. I'm assuming this was good enough for the Scottish Law Society, so I'm now unsure.

Kris

BackOfficeGroup · Guru

Kris

For your own peace of mind more than anything I would say.

I would say the solicitor did not do enough, IMHO, but then again everyone looks at the regs differently.....

P

CGA Bookkeeping Services · Veteran Member

The online checks are not to my knowledge an additional check - BackOfficeGroup - we have looked at this in order that we would no longer have to take copies of ID from clients.

Amy- thanks for the note regarding incorporating this into the Engagement Letter. That's an excellent idea!

I will have a look at the TaxCalc product you mention.

Thanks

attilabenko · Guru

As far as I know electronic checks can only substitute checks if the client is normal risk otherwise you still would have to get photo ID,etc. plus you can do additional check ie. those like TaxCalc. In my knowledge new clients cannot be low or normal risk as they are new customers you have to put them in higher risk category so you still have to get photo ID and proof of address...
You must be able to save the results of the electronic check in order to be able to access them at any time and from here comes you must register with the ICO.
If your client is not present when you carry out your due dilligence checks you must carry out additional checks as well.
So in my case I just find it much easier to get a photo ID and two additional pieces of evidence (like utility bill and bank statement) copy them and done. And it is cheaper.

Some of those above are info extracted from the Anti -Money LAundering Guidance for the Accountancy Sector issued by the Consultative Committee of Accountancy Bodies - got it in a nice looking folder from ICB ;)

Here is a link:

http://www.ccab.org.uk/PDFs/CCAB%20guidance%202008-8-26.pdf

-- Edited by attilabenko on Saturday 17th of July 2010 07:32:06 PM

BackOfficeGroup · Guru

I have never used the online system but if they do not have a photo, how can you be sure you are dealing with the correct person?

and using onlines systems means you need to be ICO registered and for many I know its an extra hassle and if not required, then no need to bother with.

P

Wella · Expert

Hi All

Having just ploughed through the MLR regs because I am not sure about the ID required for a client that is Private Ltd Company, my understanding is that photo ID is not absolutely necessary.

It depends on various factors mainly concerning risk assessment. Photo ID from a highly rated sources are classed as a strong verification source but a document to the client from a government dept/ agency or a Court (includes Companies House documents) are high on the acceptable list. The weaker the verification document, the more ID and proof of address is desirable. In theory, if the client was a relative, it would not be necessary to obtain proof of ID, if you personally knew him/ her (It's all about Know Your Client. It is all about you being sure (and being able to prove that you took appropriate steps to identify) that the client is who they say they are.

First step is the risk assessment to determine how likely money laundering laundering is.

The next step is to obtain suitable ID, relative to the risk.

In face to face meeting with low/ normal risk a photo ID, or non photo ID plus proof of address or date of birth is OK

In a non face to face or High risk, photo ID and / or several non photo proof of ID, plus several proof of address and/ or date of birth is acceptable.

Most of this has come from the ICB MLR manual section 5, which is based on the official MLR guides

Bill