Hi - I am in the process of completing the IAB form for a certificate of compliance and its asking me for i) the name of my MLRO (not sure where to get that info) and ii) a copy of my procedures for risk assessing and confirming the status of my clients. I am self employed and only have two clients and therefore don't have many intricate procedures in place. Could anyone please direct me as to where I could obtain some procedures please and advise me as to how to establish the name of my MLRO. Lastly, I don't have any insurance - is this necessary? Many thanks
you will be the MLRO (the 'O' stands for officer and it basically means you are the person charged with the responsibility of making sure all MLR procedures are carried out).
Before you act for a client you need to have satisfactorily verified their identity, the nature of their business. You must report any suspicions of money laundering.
you may want to create a check list of procedures. eg:
New Client Due Dilligence:
1. Has id of person/company been established (via company search/ copies of original documents (Passport, driving license, utility bill etc) 2. Have copies of documents been filed. 3. Have you ascertained and recorded the details of shareholders.
New Client Money Laundering Risk Assessment:
1. is client outside your normal client type/ is the trading sector unusual for you? 2. Have you met client face to face, if not is there any concerns over this? 3. Is client known to be potentially involved in illegal activities? 4. Has client been in any way obstructive/evasive when asked for information regarding ownership, the business undertaken or any other required information.
I'm sure this is not exhaustive but hopefully will satisfy IAB unless they have something for yoyu to download. In reality as an absolute minimum, get a ciopy of a photographic id and a utility bill (not mobile phone) with clients address on it.
Do not accept a company/persons with just a mobile telephone number as their contact number.
This comes direct from HMRC, although does seem a bit old hat, especially when these days, you do not necessarily need a landline number any more especially for one man bands and HMRC themselves send out correspondence with only a mobile number on it!!
So does that mean we should not take note of any correspondence from HMRC letters that only show a mobile number upon it??
FYI - I have searched 'risk assessment' on the IAB website and found a very useful document under the heading 'ANTI-MONEY LAUNDERING GUIDANCE FOR THE ACCOUNTANCY SECTOR'.
