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QBOL Certification

Anti Money Laundering

Important information for clients and prospective clients

We take our responsibilities regarding Anti Money Laundering, including financing terrorist activity and tax evasion seriously. Our policy has implications for both existing and potential clients. We will not act for anyone where we have concerns about their identity or if we have concerns about the transactions that they are associated with. For most people our duties under the law will not present a problem and although some may think that we are unnecessarily cautious please be aware that we are only fulfilling our obligations under the law, protecting the integrity of our profession and acting in the wider public interest.

Steps we always take before accepting an engagement:
We always ask prospective clients to provide us with proof of their identity. If you have an existing accountant we will always write to them to confirm that they know of no reason why we should not act for you and to obtain from them information relevant to the assignment.

In addition to these basic pre-engagement formalities we will discuss with you your business so that we can understand what you do and what you expect from us. We always consider whether we are competent to deliver the service which is being requested.

Sometimes discussions with prospective clients indicate there are risk factors and in these circumstances we may wish to make further enquiries.

What do we consider constitutes a risk?
The following list of factors, that we consider may indicate risk, is not exhaustive but it does indicate situations where we would make further enquiries before agreeing to act for a client:

Complex business structures including multiple interconnected companies and/or trusts.
Requests to use our client account to facilitate transactions.
Accounting records which are not complete.
Enterprises which are started shortly after a similar or related enterprise has failed.
Unrealistic or unusual business models.
Complex banking arrangements.
Web sites or publicity which does not reflect the underlying situation.

What additional enquiries might we make?
Where appropriate we will look into the background of companies and consider, for example, who set them up, who are, and who have been the directors, and who are the shareholders. We will obtain this information from Companies House and in discussions with you.

We might ask prospective clients about previous, and other existing business activities and whether these have been successful. Unsuccessful business enterprises are not necessarily an indication of poor management or flawed business models but they might be and it is important that we consider the possible implications.

We may seek confirmation of relevant qualifications that you hold.

We may consider the business model in detail and whether or not it is realistic in all the circumstances.

All of these steps and any others we decide to take are so that we comply with the Anti Money Laundering legislation and with Client Due Diligence in accordance with the obligations we have as a member firm of the Institute of Chartered Accountants. We thank you in advance for your understanding and co-operation.

 

 

"We take our responsiblities regarding Anti Money Laundering, including financing terrorist activity and tax evasion seriously"