In June 2017, HMRC released the updated publication of the new Money Laundering Regulations, which outlines general businesses daily responsibilities to ensure customer due diligence checks are made.
What do you need to do to comply?
Understand customer due diligence, are you customers who they say they are? Ensure you have their name, address, date of birth and official photo ID. If you have any concerns regarding a customer’s identity, the best measure is not deal with them until you have the supporting information.
Other acceptable documents could include:
- Bank statements, bills
- Electoral register
- Experian reports and other credit reference agencies
- Official documents
Customer due diligence should be carried out at the start of a new business or customer relationship, in the event circumstances have changed, or when you might suspect the information you have been given is incorrect.
The Updated Money Laundering Regulations have set information requirements for due diligence for:
- New customer relationships
- New business relationships
- New customer circumstances
- New occasional transactions, or linked transactions
In some situations, for transactions under 15000 Euros, the regulations require ‘enhanced due diligence’. This would occur when the customer is not present when identification checks are made, or the circumstances are deemed as high-risk for money laundering. Enhanced checks would include gaining further information to confirm the customer’s identity, checking the source of the payment, and that it is from the customer’s named account.
The Money Laundering Regulations require businesses to ensure internal monitoring systems are in place to provide warning alerts in the event your business is unlawfully used for money laundering. Should a money laundering attack occur, preventative measures must be put in place to stop any repeat attacks.
Internal controls outlined by HMRC include ensuring that employees know to highlight suspicious online activity to an assigned staff member or compliance officer. Senior managers should also receive regular information on preventing money laundering and what the current policies and control procedures are. Risk factors should be considered and protected when planning day-to-day business activities.
For more information on how these regulations will impact your business, please speak with us, or visit the HMRC website to find out who needs to register.