My client is not particularly happy, if not downright refusing, to give me the ID information I need for my Money Laundering Due Diligence records. Basically because he has never had an "employee" ask for such information before.
Has anyone else had this problem and what should I do. They are a good customer in every other way and clearly run an honest business.
My client is not particularly happy, if not downright refusing, to give me the ID information I need for my Money Laundering Due Diligence records. Basically because he has never had an "employee" ask for such information before.
Has anyone else had this problem and what should I do. They are a good customer in every other way and clearly run an honest business.
Sue
There is your problem, your client is not seperating you from his employees You are self employed, and have a legal duty to obtain the information. This needs to be conveyed to your client.
I think it is because clients often see that bookkeeping is an internal function of their business. If you were a builder, adding an extension to their office they wouldn't see you as an employee, even though it was for the business
If he wants to employ you, and give you sick pay, holiday pay and have all the additional admin of running payrol for you, then you don't need to do the due diligence.
At the end of the day it is down to you but so is the comeback, if you don't carry out due diligence.
OK thanks. Thats what I thought really. No way round it. If he won't provide me with it I have a problem. I will have to sit down and talk to him about it. Sue
I have never heard of anyone having any objection to providing the information needed.
At the end of the day it is just a copy of their passport/driving licence and something like a utility bill which the time to sit down and explain why you need it etc will probably take longer than just copying the docs.
It still surprises me when I hear this type of issue. If you get really stuck there are alternatives to turning away the business. You could look at electronic ID verification which would mean you don't have to get this information from your client. You could then either take the cost as an expense or as a lot of people do charge it to the client as part of your fees. Stangely enough people are less likely to question a small fee as part of the set-up.
if you use that sort of service you need to be registered for data protection.
It's no biggy to register but just to be aware that companies shouldn't give out that sort of info if your not registered.
(That's my understanding but someone will probably now correct me on that one).
Kind regards,
Shaun.
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Shaun
Responses are not meant as a substitute for professional advice. Answers are intended as outline only the advice of a qualified professional with access to all relevant information should be sought before acting on any response given.
Agreed Peasie, it amounts to the same thing but I find it easier to say I have to run some ID checks than to give someone the impression they're in front of a Customs Officer.
As a matter of interest, a new one called by a few months ago and handed me a passport and driving license photocopies without my asking. This made me more suspicious, not less.
Agreed Peasie, it amounts to the same thing but I find it easier to say I have to run some ID checks than to give someone the impression they're in front of a Customs Officer.
Do they need to sign to give you permission or is verbal enough?
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Never buy black socks from a normal shop. They shaft you every time.
I don't know Peasie. Although I fully support the anti-terrorism / drug / crime aims we could very easily spend more time dealing with bureaucracy than making a living.
I think our institute's only bang on about the ID side because its something they can monitor. In other words, I so rarely come into contact with likely drug dealers that there'd be no way of knowing if I was complying or not. Tim
The way I see it, it is my reponsibility to carry out due diligence, which means i can take any legal means necessary, which would include any of the online sources. In fact initially, as a rough guide I use tyhe website you put us on to Duedil, which is a great free resource for checking Directors (Suspect they got the name Duedil from DueDiligence)
What I hadn't realised until recently, is that it is not necessary to carry out due diligence on one off contracts, as long as the value does not excede 15000EU. Although I probably still would
There is an assumption by those better than us (!) that the 99.9% of law abiding people are actually guilty of something and that the professionals who deal with said law abiding people are stupid - and it should be the other way around. Most of us here are aligned to a professional body of some description and it should be good enough that we sign a declaration that if we suspect something or someone of being dodgy we will report it to said better people !!!!! MLR is a job creation scheme and is a mallet to crack a peanut
Exactly, According to the contented builders on the site where everyone got a refund, the accountant was never available on a landline phone but on his mobile you could hear the gentle lapping of the Caribbean waves and chinking of champaign glasses.
I don't want to profit from ill-gotten gains - in fact ........ soccer report did not feature a customer.
I did a little digging with the info I had and there was no mention of him at the practice address given.
Now then, how can we get to grips with organised crime.
........and there are enough examples in 20th C history of how it goes when everyone is an employee of the state.
I had a Russian girlfreind for a while who absolutely hated perestroica as beforehand everyone had work and whilst things were not perfect (her own Dad spent time in a Gulag during the Stalin era) the people had stability and food and medicine and a car.
In the wake of capitalism the Mafia used the soldiers (and weapons) that the state no longer wanted to take over everything in the new "free" Russia so it was because of capitalism that she left, not communism.
Always strange to get the alternate view of imposed freedoms from the people who lived it.
Mmmm, now where's her phone number gone!
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Shaun
Responses are not meant as a substitute for professional advice. Answers are intended as outline only the advice of a qualified professional with access to all relevant information should be sought before acting on any response given.
Shaun, we can't just have Roman Abramovich winning everything lol
Russia had been failing for decades and were just hanging on after abandoning the gulags and eschewing a market of any worthwhile products. I had a girlfriend in Russia who said the KGB were just another name for the Mafia. No good can come from a society based on compulsion. The KGB controlled anything outlawed and anything surplus because there was no opposition. Simples. The troops in Afghanistan suddenly got a more ready and cheaper supply. Tim ;)
Yes, Experian is one provider and is the one we use with our clients, but there are a number of companies offering this solution. To make sure you cover all money laundering bases just make sure that whichever you choose ticks the following:
Cover a wide range of data sources to prove the ID Gives you a full audit trail and allows you to produce a report Covers some negative data sets. Most should cover things like financial sanctions, deceased database, accommodation addresses and politically exposed persons (PEPs)
Regarding data protection, mentioned above, this isn't specific to doing these checks. If you are holding any data electronically, which I assume you would be, it is a good idea to be registered. The Information Commissioners Office did a recent trawl of estate agents and a lot ended up with a £250 fine for not being registered.
The one final point raised was around the consent side of things. You do need to inform the client that you are going to to the check, an email or something is OK, you can even do it verbally but keep a note or send a confirmation email. The check doesn't impact the individual's credit history in any way but it will leave a marker on their credit report saying their identity has been checked. This is just to have end to end transparency.
I have used creditsafe for several years now to collect the director info however I also ask for manual info too. I have covered obtaining the info by mentioning it in my letter of engagement which they sign. Also registered for data protection.
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Donna Curling - Complete Book-Keeping Ltd (CBKLtd) - 07939 101900
