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AML - opinions wanted

  • Member
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  • # 118848

Hope I am posting this in the correct place.

I am just watching the ICB webinar on AML and it has made me think about one of my clients...

Client has several companies and does numerous inter-company loans and also invoices for 'consulatncy services' between companies. Amounts involved are usually over £10k. I have always felt uncomfortable about these and have asked what they are for; inter-company loans are for cash flow purposes and are repaid, but I'm not sure about the consultancy service invoicing.

Should I report a SAR, or just start asking more questions..? Client has two accountants on board (migrating from a sole one about to retire to an accountancy firm), so I kind of feel as though everything is above board.

I would appreciate opinions!

 

  • Fellow PM.Dip
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  • # 118849

KLB2006 said:

Hope I am posting this in the correct place.

I am just watching the ICB webinar on AML and it has made me think about one of my clients...

Client has several companies and does numerous inter-company loans and also invoices for 'consulatncy services' between companies. Amounts involved are usually over £10k. I have always felt uncomfortable about these and have asked what they are for; inter-company loans are for cash flow purposes and are repaid, but I'm not sure about the consultancy service invoicing.

Should I report a SAR, or just start asking more questions..? Client has two accountants on board (migrating from a sole one about to retire to an accountancy firm), so I kind of feel as though everything is above board.

I would appreciate opinions!

 


 I would personally give ICB a call and speak to one of the team. Get advice from them as to whether you need to submit a SAR

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  • # 118850

I would discuss with ICB if you have doubts

Does Companies House filing reveal any wrong doings?

If loans are involved are any debentures in place as charges?

Might be worth checking for other directorships for the directors

There may also be other companies that you do not know about

Might be all above board but you can check quite a bit

I did a check on one of my suppliers a couple of years ago

and they found 13 bars of gold bullion in the safe!

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