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AML procedures - annual reviews - help please!

Jason SHB
  • Member PM.Dip
  • Practice Licence
  • 13 posts
  • # 113254

Hello, 

 

I would love to find a definitive answer (or at the very least a consensus of opinion of what is being done by most and accepted as correct).

 

If you can point me in the direction of a 'clear and easy to follow' (I appreciate when it comes to AMl, this may be a tall order) link which may help explain this to my admin lady and/or a client of they ask. I see this doesn't appear to be explained on the ICB website, unless I've missed it.

 

When I first engage with a client I am clear in what I need to undertake to comply. Currently the majority of my clients provide a passport (identification) driving licence (address verification). Of course, I ensure these documents are not in date.

 

When I annually review my clients, this is where I am unsure if I am doing the correct procedure:

 

1. Do I need to take replacement address verification in all cases?

2. Do I need to take replacement identification in any cases?

3. What are the guidelines for asking for replacements documents and do I need to meet the client again or can they email me a copy (obviously it won't be verified).

4. Are all documents meant to be verified - even those I have taken a copy of myself?

 

So many questions and would appreciate what procedures others of you follow each year and how you manage the process to keep compliant and up to date.

 

I have recently sign-up to a CRM system to help me manage it and send me reminders... although I appreciate this is not necessary and maybe a once a year process to contact all new clients maybe a better process (although this means they maybe more than a year out of date) ... or I could repeat if twice a year to capture anyone I didn't write to 6 months ago.

 

I feel as though I am over-0thinking this... but want to do it right and make it most efficient.

 

All help and advice is gratefully received.

 

Ta! Jase
Lady of Ledger
  • 491 posts
  • # 113256

Hi Jase

Having been to the Bookkeepers Alliance Conference yesterday in Birmingham, and attending a workshop that discussed this exact subject - I hope I can clarify some of your questions for you:

First of all, if the document is in date you would not be required to renew until out of date - i,e, a driving licence that does not expire until 2022, as long as the client does not move address, then you will not need to replace the document each year.

However, if you are given a driving licence in June 2016, that expires in Jan 2017, then in Jan 2017, you will be required to ask for a new ID document, being either a renewed driving licence, or an alternative qualifying document.

All documents are ideally supposed to be certified - this can be done by you if you're with the client at the time that they give you the document, so you are verifying that the photo is a true likeness of the client - if you can't be there yourself, then ideally, you should ask them to get their ID certified by a solicitor to be squeaky clean for your files.

The Company that was at the conference was AMLCC - their website is amlcc.co.uk if you're interested

Hope that helps with some of your questions.

  • Carol Saunders
    Lady of Ledger Book Keeping
    Telford, Shropshire



  • Quote
KathrynH
  • 28 posts
  • # 113411

Hi Jase,

In addition to what Carol has said the Direct.gov states that customer due dilligence measures should be carried out if any of the following apply:

  • when you establish a business relationship
  • when you carry out an ‘occasional transaction’ worth €15,000 or more
  • when you suspect money laundering or terrorist financing
  • when you have doubts about a customer’s identification information that you obtained previously
  • when it’s necessary for existing customers - for example if their circumstances change

So if existing customers change their name, address, marital status etc. you may like to ask them for relevant identity documents that make the changes clear.

The direct.gov pages are quite a good summary and can be found here https://www.gov.uk/guidance/money-laundering-regulations-your-responsibilities

Hope this helps.

Best wishes,

Kathryn



Edited at 18 Jul 2016 11:39 AM GMT
  • Lifetime Member
  • 9 posts
  • # 113907

I am one of the ICB's AML Compliance Officers and I can clarify the situation for you here.

Once you have satisfactorily identified a client their identity will not change. So as long as the documents you use are in date when you see and take a copy of them then you do not need to replace those documents if they subsequently expire. If the person's name changes, for example when a woman marries she usually changes her family name, then you need a replacement document at that time.

As for address confirmations, as long as you know the client is still at the same address then the original document will remain valid indefinitely.

This topic actually cropped up at one of the workshops at this year's ICB Summit and the Compliance Director confirmed what I have just said.
Jason SHB
  • Member PM.Dip
  • Practice Licence
  • 13 posts
  • # 113908

Chris B said:

“

I am one of the ICB's AML Compliance Officers and I can clarify the situation for you here.

Once you have satisfactorily identified a client their identity will not change. So as long as the documents you use are in date when you see and take a copy of them then you do not need to replace those documents if they subsequently expire. If the person's name changes, for example when a woman marries she usually changes her family name, then you need a replacement document at that time.

As for address confirmations, as long as you know the client is still at the same address then the original document will remain valid indefinitely.

This topic actually cropped up at one of the workshops at this year's ICB Summit and the Compliance Director confirmed what I have just said.

”

Hi Chris B,

 

Thank you. I have subsequesntly received a respinse from Ray Cross. I have also raised another question. I didn;t post iot here as the answers appear to be unreliabel and inaccurate (I too heard the Birmingham conference and didn't trust it, whch Ray confirmed was rubbish - others appear to have believed it).

 

The other questions was regarding reselling software (I do this for some clients, where I pass-on my discount but offer no bookkeeping) - do we need to insist on AML. I assume yes, but my client wanted to check. I asked and have yet to receive a reply. Please could you answer my questions or chase Ray to repsond to my emial please.

 

Many thnaks,

 

Jase
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