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Stardoe


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Temporary client - money laundering regs
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Hi guys,

Hope everyone is coping with the snow and managing to get about!

This is probably a question for James, did mean to ring the ICB today, but got so busy that I forgot!  I do some occasional sub contract work for an accountant and he telephoned me yesterday asking if I'd be interested in doing just a few hours work for a firm whose bookkeeper has gone sick for three weeks.  It will literally be 2 or 3 days in total, just to get them up to date.

My question is, do I have to go through all the money laundering ID regs and due diligence form filling for just a couple of days work, or as I am doing this through the accountants, will I be covered by them? 

Any advice appreciated as usual  smile.gif

Pauline

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Pauline
Quentin Pain


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What a great question Pauline.

Since you are working for the accountant (they are paying you, not the client?), they will have already done the due dilligence.

Can you imagine if every employee, part timer, sub-contractor needed to check each client out as the business was passed around the firm. If I am wrong (and it is too late to check with HMRC tonight) I will eat my ledger :)

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Stardoe


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Hi Quentin, thanks for the quick reply   smile.gif   Yes the accountant will be paying me not the client, but I'm not sure that the accountant has done the due diligence as this isn't a regular client of theirs, it was a panicked phone call to them to find a Sage bookkeeper as they had a VAT return due.  Perhaps I should check?  I'm going to see the client Friday afternoon to see what he needs doing.

Pauline

P.S.  Can I watch you just eat your ledger anyway?  wink.gif

-- Edited by Stardoe on Wednesday 1st of December 2010 10:53:09 PM

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Pauline
Quentin Pain


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Yes of course you can :) I am just having it cleaned up a little, got any Worcester anyone?

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ICBUK


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Morning all,

Quentin you might have to start eating :)

You can only accept due diligence from an accountant if they are supervised by a body listed under part 1 of Section 3.

Those bodies are:

  • Association of Chartered Certified Accountants
  • Council for Licensed Conveyancers
  • Faculty of Advocates
  • General Council of the Bar
  • General Council of the Bar of Northern Ireland
  • Institute of Chartered Accountants in England and Wales
  • Institute of Chartered Accountants in Ireland
  • Institute of Chartered Accountants of Scotland
  • Law Society
  • Law Society of Scotland
  • Law Society of Northern Ireland
If they are not registered with one of the above you have to do your own due diligence I'm afraid.

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Anna

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Stardoe


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Hi James,

Thanks for the reply smile.gif They are registered under the ACCA, so I assume I'm ok then?

Pauline

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Pauline
ICBUK


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Hi Pauline,

Yes, you need a letter from them on their letterhead (with their ACCA supervision number somewhere on it) stating they have done due diligence and they are happy for you to accept that.

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Stardoe


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Thanks James.  It seems to be so much trouble to go to just for a client that only wants a couple of days work just whilst his (employed) bookkeeper is off sick.

Pauline

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Pauline
Quentin Pain


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Hi James, Phew! I had the Worcester ready to go as well ;)

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Stardoe


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Awww...don't worry Quentin, I wouldn't have forced you smile.gif (much)

Pauline

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Pauline
lor


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Quentin Pain wrote:

What a great question Pauline.

Since you are working for the accountant (they are paying you, not the client?), they will have already done the due dilligence.

Can you imagine if every employee, part timer, sub-contractor needed to check each client out as the business was passed around the firm. If I am wrong (and it is too late to check with HMRC tonight) I will eat my ledger :)


ledger taste quite nice, sorry couldn't resist!

 



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Quentin Pain


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lor, tell me more? I will happily swap my ledgers for a better taste ;)

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