Paula Veysey-Smith C.FICB explains what she did when a potential client set AML alarm bells ringing
Now, what possibly could a 1990’s film starring the late, but great, Robin Williams has to do with money laundering? Well, we have a new catchphrase in our business, “A Mrs Doubtfire”, and I shall share with you how it came about!
We were just onboarding a new client, a director of a new and small limited company. The Letter of Engagement had been returned, passport and proof of address viewed, and copies were taken, and Companies House checks completed. I guess that meant I had crossed my t’s and dotted my I’s and was ready to set up the new client on AML online! Just one last check, I thought, as I tapped their name into Google and I nearly fell off my chair when my search results showed various articles about the client's involvement in a US fraud case. Now I can’t go into too much detail but suffice to say the amounts of money involved were not small.
The phrase 'bunny caught in headlights' could be used to describe how I looked at that moment! The seemingly perfect client was now resembling the main character from the film Wall Street. What was I to do? Running away sprung to mind, but here’s the thing, I had properly done my due diligence and although what I had found was a game-changer it was not necessarily a deal-breaker! Why? I believe mainly for this reason. I am aware of my client’s history, which will be declared on the AML record, so I will keep a close eye of them as a high-risk client, and if I believe there is any suspicious activity, I know exactly what to do. If I’d not taken up the engagement would the new bookkeeper be so diligent? I felt a moral responsibility to continue the engagement. With the proper safeguards in place why forego what could be a good client. I also believe that people should not be trapped in their past, we all make mistakes! So, will the extra monitoring be worth it… time will tell!
So, why a Mrs Doubtfire? Well, she, or should I say he, wasn’t quite what they seemed. People are very good at covering things they may not want others to see or know, just like Robin Williams in the film, and we mustn’t assume that because we like them, they must be OK. Don’t take people at face value and do everything you can to check that they are not wearing a mask! I’m not saying that we need to be continually suspicious, but we certainly need to be constantly alert.
And remember, if you do have doubts, there may well be fire! Be watchful for your Mrs Doubtfires.
Paula Veysey-Smith C.FICB is chair of ICB’s Advisory Council and founder of M: Power Accounting Services Ltd.
