Know Your Customer/ Money Laundering
Discussion
I know that I am also supposed to be checking my client's ID etc. Certainly all new clients will have to provide me with some form of supporting ID when we first meet.
I have to say, in almost 30 years of working in accounting, I have NEVER, EVER come across ANY individual who gave a false identity - and I have dealth with THOUSANDS of clients in that time period. It is actually a very rare occuremce in accounting - although probably not so rare in the banking world.
I have to say, in almost 30 years of working in accounting, I have NEVER, EVER come across ANY individual who gave a false identity - and I have dealth with THOUSANDS of clients in that time period. It is actually a very rare occuremce in accounting - although probably not so rare in the banking world.
Eric Mc said:
I have to say, in almost 30 years of working in accounting, I have NEVER, EVER come across ANY individual who gave a false identity
... that you were aware of ...
How do elephants hide in cherry trees? They paint their toenails red.
Have you ever seen an elephant in a cherry tree? No? That shows how well it works...
They would have to have been exceedingly clever to hide their identity for the length of time you tend to have clients. Clients usually remain clients with their accountants for decades. I know there is the possibility that some might have managed it - and I have dealth with clients who used more than one name (for business or professional purposes m'lud 
).
However, I think banking is more vulnerable to impersonation as it involves REAL money as opposed to accounting, which tends to involve the REPORTING of monetary matters, rather than dealing with the real stuff.
). However, I think banking is more vulnerable to impersonation as it involves REAL money as opposed to accounting, which tends to involve the REPORTING of monetary matters, rather than dealing with the real stuff.
Until recently I worked in a "Big4" Accountancy firm. Even though I was angaged purely in consulting work I had to complete in depth money laundering training.
IMO much of the kyc stuff was pretty useless. The type of work I was involved in would not really expose me to the info required to determine if one of my clients (Footsie 250) was involved in money laundering. Most people would do the on-line training & promptly forget about it. THe firm took it seriously as failure to complete the training was a displinary offence. Each new client also needed a money laundering check to be performed before any work could be done for them. Again, failure to do this would be detrimental to ones career!
Colleagues involved in audit did pay a bit more attention as they would have some legal responsibility if the client was subsequently found to be laundering money. There were strict guidelines on the whole process including stuff like tipping off, escalation etc. Unfortunately I deleted all the material so haven't got anything useful for reference.
IMO much of the kyc stuff was pretty useless. The type of work I was involved in would not really expose me to the info required to determine if one of my clients (Footsie 250) was involved in money laundering. Most people would do the on-line training & promptly forget about it. THe firm took it seriously as failure to complete the training was a displinary offence. Each new client also needed a money laundering check to be performed before any work could be done for them. Again, failure to do this would be detrimental to ones career!
Colleagues involved in audit did pay a bit more attention as they would have some legal responsibility if the client was subsequently found to be laundering money. There were strict guidelines on the whole process including stuff like tipping off, escalation etc. Unfortunately I deleted all the material so haven't got anything useful for reference.
The tipping off rules are dreadful -
1. You only have to be "suspicious" of your client to make it obligatory to notify NCIS
2. You cannot notify the client in any way that you have informed NCIS - that is "tipping off".
3. If you are pretty sure that your client MAY have been involved in anything unsavoury, your professional body will probably expect you to cease to act for that client. If you do not, you may subsequently fall foul of your Institute's/Association's internal disciplinary procedures. However, if you resign from your position, you are ethically obliged to notify your client and give them a reason. If you tell them the truth as to why you are resigning, you will have committed a crime under the Proceeds of Crime and Money Laundering Regulations. If you tell them a lie you will have breached your professional body's ethical guidelines. If you tell a lie but the client actually knows or is pretty sure why you are resigning, you will have committed a crime too as that is still "Tipping Off".
4. If your client imdulges in even a minor infringement - like overclaiming business expenses or using a slightly inaccurate business/private split of expenses, that is a crime under these new rules and must be notified to NCIS by the accountant.
5. If your client is the VICTIM of a crime, the accountant must also notify NCIS, even if the police are already aware and the culprit(s) apprehended.
Failure to notify NCIS in any circumstances constitutes a criminal act by the accountant. Under these rules there are no petty crimes. All must be notified. This was confirmed by Dawn Primorolo when asked this specific question last year.
1. You only have to be "suspicious" of your client to make it obligatory to notify NCIS
2. You cannot notify the client in any way that you have informed NCIS - that is "tipping off".
3. If you are pretty sure that your client MAY have been involved in anything unsavoury, your professional body will probably expect you to cease to act for that client. If you do not, you may subsequently fall foul of your Institute's/Association's internal disciplinary procedures. However, if you resign from your position, you are ethically obliged to notify your client and give them a reason. If you tell them the truth as to why you are resigning, you will have committed a crime under the Proceeds of Crime and Money Laundering Regulations. If you tell them a lie you will have breached your professional body's ethical guidelines. If you tell a lie but the client actually knows or is pretty sure why you are resigning, you will have committed a crime too as that is still "Tipping Off".
4. If your client imdulges in even a minor infringement - like overclaiming business expenses or using a slightly inaccurate business/private split of expenses, that is a crime under these new rules and must be notified to NCIS by the accountant.
5. If your client is the VICTIM of a crime, the accountant must also notify NCIS, even if the police are already aware and the culprit(s) apprehended.
Failure to notify NCIS in any circumstances constitutes a criminal act by the accountant. Under these rules there are no petty crimes. All must be notified. This was confirmed by Dawn Primorolo when asked this specific question last year.
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