AML Document : Company : Certificate of incorporation reviewed and filed?
AML Document : Company : Copy of latest annual return (within last 12 months) reviewed and filed?
AML Document : Company : List of all authorized signatories (with verification of their identities) reviewed and filed?
AML Document : Company : List of all Directors (with verification of their identities) reviewed and filed?
AML Document : List of all shareholders holding > 10% paid up share capital (with verification of their identities) reviewed and filed?
AML Document : Partnership : A List of all authorized signatories (with verification of their identities) reviewed and filed?
AML Document : Partnership : A List of Current Partners (with verification of their identities) reviewed and filed?
AML Document : Partnership : Copy of Partnership Agreement duly Notarized reviewed and filed?
AML Document : Sole Trader : A copy of latest annual return reviewed and reviewed and filed?
AML Document : Sole Trader : Certificate of Registration reviewed and filed?
AML Document : Trust : A List of all parties to the Trust (with verification of their identities) reviewed and filed?
AML Document : Trust : A List of all persons authorized to transact business on behalf of the Trust (with verification of their identities) reviewed and filed?
AML Document : Trust : Copy of Trustee Agreement duly Notarized reviewed and filed?
AML Document: Company : By laws reviewed and filed?
Client Risk : Are the clients organisational activities reviewed and recorded on file?
Client Risk : Are there full details of the client reviewed and filed?
Client Risk : Client Contact : Person : Have we met the client in person/physically? If not do we think there is a legitimate reason for this?
Client Risk : Client Contact : Where acting on behalf of someone else, do you have details of the identity of that person?
Client Risk : Company : ID and Verification : Have we determined the involvement of the beneficial owner or owners of the organisation, and or anyone who may otherwise exercise control over the management of the company and have these recorded on file?
Make note of the ultimate beneficial owner.
Client Risk : Financial Profile : Is your client involved in or do they run a high risk or high cash turnover business?
Client Risk : Financial Profile : Source of Wealth : Are we aware of the clients general financial circumstances? i.e. Does the stated source of wealth, source of funds, the amount of money involved match with what you know of your client?
Client Risk : Financial Profile : Source of Wealth : Do the clients general financial circumstances appear to have been obtained in a legal fashion?
Client Risk : Financial Profile : Source of Wealth : Does the clients source of wealth appear to originate from a local jurisdiction?
Client Risk : General : Are we being asked to complete work that is our business as usual or something different?
Client Risk : General : Has adverse media screening been completed?
Client Risk : General : Have adequate checks been undertaken on the clients identity to comply with Money Laundering Regulations (AML)?
Also record the dates these checks were carried out as they may need to repeated after a fixed term depending on regulations, or for example if the client name changes e.t.c.
Client Risk : General : Was the client straightforward and willing to provide information required for anti money laundering, i.e. they have been cooperative and not delayed?
Client Risk : ID and Verification : Are we dealing with the ultimate client and not an intermediary who could be hiding their identity?
Client Risk : ID and Verification : Do we fully understand the control and ownership structure of the client and have this recorded on file?
Client Risk : ID and Verification : Do we have a certificate of shareholding for the client?
Client Risk : ID and Verification : Have we ascertained and recorded the nature of the organisation?
Client Risk : ID and Verification : Have we assessed the integrity of the owners, directors (or equivalent), and management of the organisation, and where applicable have their name, address ,work or mobile number, home/work email, VAT, tax File or IRD?
Ensure all details recorded, e.g. Titles, first name, middles names, last name etc.
Client Risk : ID and Verification : Have we recorded evidence of the clients full name, their address/residence, their work and mobile numbers, their work and home email addresses, their VAT, tax File & IRD numbers?
Client Risk : ID and Verification : Have we recorded evidence of the clients gender, date of birth or date of incorporation?
Make note of registered office address where applicable.
Client Risk : ID and Verification : Have we recorded evidence of the organisation?
Client Risk : ID and Verification : If it is an individual do you have copies of and official document such as their passport, photo driving licence or national identify card and are they genuine?
Ensure details are recorded and noted. e.g. Driving licence number, passport number, expiry date, country of origin, type of document e.g. passport/identity card etc.
Client Risk : ID and Verification : If the client is in a regulated industry, have we enquired about its relationship with the regulatory authorities?
Client Risk : ID and Verification : In case of involvement, you need to check the ultimate beneficial owner (full name, a photograph of official documents, residential address), and the relationship between the beneficial owner and client.
Client Risk : ID and Verification : Person : Where identity is verified electronically, or via copies, apply an additional verification check to manage the risk of impersonation fraud. Eg. require copies to be to be certified by an appropriate person.
Client Risk : ID and Verification : Where applicable, do we have the companies registration number, their address, status, VAT, tax, GST number?
Client Risk : Location of Client : Is client based locally or overseas?
Client Risk : Status of Client : Do we know why the client has chosen our firm, and have we recorded this?
Client Risk : Status of client : Has client or their instruction been introduced or channelled by a 3rd party or are they acting on their own behalf?
Client Risk : Status of client : Has the source of any introduction been established,i.e known personally, existing client or new business relationship?
Client Risk : Status of Client : Have we performed a credit search?
Client Risk : Status of Client : Is there any known or suspected criminality, for example, money laundering, theft, fraud, terrorism, drug offences or identity fraud, of the person or organisation?
Client Risk : Status of Client : Redflag: Directly, or indirectly, are the client, owner, or other entity of the company, or associated family members, or known associates politically exposed people (PEPS)?
Client Risk : Tax : Are the all of the clients tax affairs up to date?
Client Risk : Tax : Has the client been under enquiry from HMRC?
Client Risk : Tax : Have we notified tax authorities e.g. Her Majesties Revenue and Customs (HMRC) of our appointment as a supplier or advisor if applicable?
Client Risk : Tax : Is or should the organisation or individual be registered for Value Added Tax (VAT)?
Client Risk : Tax : Is there a chance the business could be misappropriating Tax or VAT?
Risk : General : Are all the records for each customer stored and ready to provide by regulators request if required?
Transaction Risk : Destination of Funds : Are free proceeds to be paid to an overseas account?
Transaction Risk : Destination of Funds : Has your client requested that free proceeds be paid to someone other than a lender or themselves?
Transaction Risk : Source of Funds & Payments : Are banks from our own jurisdiction used and do we have details of the name of the bank, bank branch address, bank account number, IBAN & Swift Code, do we have evidence?
Transaction Risk : Source of Funds & Payments : Company & Person : Are funds and payments being made to and from banks that are themselves subject to AML measures?
Transaction Risk : Source of Funds & Payments : Is the transaction straight forward and is understood to be commercially correct?
Transaction Risk : Source of Funds : Are payments to us from something or someone other than a bank?
Transaction Risk : Source of Funds : Are payments to us made in cash?
Transaction Risk : Source of Funds : Company & Person : Are any of the funds being paid by a third party otherwise unconnected to the transaction?
Transaction Risk : Source of Funds : Did your client seek to change the source of funds at the last minute?
Transaction Risk : Source of Funds : Do we know from where (source) the client is funding the transaction?
Transaction Risk : Source of Funds : Has your client paid excess funds into your client account? Why/How?
Transaction Risk : Source Of Funds : If any funding coming from overseas, where from? Who from? Connection to client?
Transaction Risk : Source of Funds : Redflag: Are there any unexpected patterns of activity in funding (transaction types, frequency of transactions etc).
Transaction Risk : Source of Funds : Redflag: Is the method of payment unexpected?
Transaction Risk : Transaction Type : If the client is organising money movement, investments, land, buildings or setting up new companies is there good reason for that?
Transaction Risk : Value of Transaction : Does the value of the transaction appear to fall within the financial means of your client, given their income and savings?
Transactional risk : Are elements of the work subject to the market abuse regulations and therefore subject to insider lists?
As required by Article 18 of the UK Market Abuse Regulation, a list maintained by issuers (or any person acting on their behalf or on their account) which includes details of all persons who have access to inside information and who are working for them under a contract of employment, or otherwise performing tasks through which they have access to inside information, such as advisers, accountants or credit rating agencies.