AML Notice

About this Anti-Money Laundering Notice

MBS Accounting Ltd provides accounting, tax and business advisory services. As an accountancy service provider, we are required to take appropriate measures to help prevent money laundering and other forms of illicit finance.

This Notice explains, at a high level, why we may request information from clients, the checks we may carry out and how our legal and regulatory obligations can affect the services we provide.

It is a public summary only. It does not replace our internal anti-money-laundering policies, controls, procedures or risk assessments.

Our approach Risk-based and proportionate

Client checks Identity and ownership verification

Ongoing obligation Monitoring and record keeping

Our anti-money laundering obligations

The UK anti-money-laundering framework requires relevant accountancy businesses to maintain appropriate policies, controls and procedures designed to identify and manage financial-crime risk.

Know our clients

Identify clients, verify relevant information and, where applicable, establish who ultimately owns or controls an organisation.

Understand risk

Assess the nature of a client relationship and apply additional checks where the circumstances indicate a higher level of risk.

Monitor and report

Keep relevant information under review and meet applicable reporting obligations where suspicious activity is identified.

Legal and regulatory framework

Our anti-money-laundering procedures take account of legislation and guidance applicable to the services we provide, including, where relevant:

Money Laundering Regulations

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.

Proceeds of Crime Act

The Proceeds of Crime Act 2002, including applicable obligations relating to suspected money laundering and criminal property.

Terrorist financing

Relevant requirements under the Terrorism Act 2000 and associated legislation.

Current guidance

Applicable guidance issued by government, supervisory authorities and other competent bodies.

Customer due diligence

Before establishing or continuing certain business relationships, we may need to establish who our client is and understand the nature and purpose of the relationship.

Depending on the client and the services involved, our checks may include:

Identity

Confirming the identity of the person or organisation engaging MBS Accounting.

Ownership and control

Identifying beneficial owners and understanding relevant ownership or control structures.

Purpose

Understanding why our services are required and the intended nature of the business relationship.

Risk

Considering relevant financial-crime risks associated with the client, services, activities and circumstances.

Further information

Requesting additional evidence or explanation where necessary to complete our checks or understand a matter.

Information we may request

The information required will depend on the nature of the client and our risk assessment.

Individuals

Personal verification

Full name
Date of birth
Residential address
Photographic identification
Evidence of address where required
Information about the purpose of the relationship
Source of funds or wealth where appropriate

Organisations

Business verification

Legal and trading name
Company or registration details
Registered and business addresses
Directors or responsible officers
Beneficial owners
Ownership and control structure
Nature and purpose of the business relationship

We may use reliable independent sources and electronic verification services to assist with identity and anti-money-laundering checks.

Our risk-based approach

Anti-money-laundering checks are not necessarily identical for every client. We assess relevant risks and apply measures that are appropriate to the circumstances.

Where a relationship presents a higher risk, legislation or our assessment may require enhanced due diligence, additional evidence, further approval or closer monitoring.

Client profile Business activities Ownership structure Geographical exposure Services requested Transaction patterns Political exposure Other risk indicators

Ongoing monitoring

Anti-money-laundering obligations do not necessarily end once a client has been onboarded.

Initial onboarding

We obtain and assess the information necessary to establish the relationship and complete appropriate checks.

During the relationship

We may consider whether activity and information remain consistent with our understanding of the client and the services being provided.

Material changes

We may request updated information where ownership, activities, circumstances or other relevant factors change.

Periodic review

Client information and risk assessments may be refreshed periodically where appropriate.

Suspicious activity and reporting

Persons working within the regulated sector can have legal obligations to report knowledge or suspicion of money laundering, terrorist financing or other relevant suspicious activity.

Where the legal reporting threshold is met, information may need to be reported through the appropriate channels, including the UK Financial Intelligence Unit within the National Crime Agency.

Confidentiality restrictions may apply. In certain circumstances, the law may prevent us from confirming whether a report has been made, is being considered or whether particular information has been provided to an authority.

If we cannot complete our checks

We need sufficient information to satisfy applicable legal, regulatory and risk-management requirements.

Delay onboarding We may postpone the commencement of services until required checks have been completed.

Request further evidence We may ask for additional documents, information or clarification.

Decline or cease services Where necessary, we may be unable to establish or continue a professional relationship.

AML records and personal information

We maintain records associated with our anti-money-laundering obligations, including relevant due-diligence and risk-assessment information.

5 years General AML retention period

Relevant AML records are generally retained for five years from the end of the business relationship or completion of the relevant transaction, subject to applicable legal requirements and exceptions.

Personal information obtained for these purposes is also handled in accordance with applicable data-protection requirements. Further information is available in our Privacy Policy.

What we require from clients

Effective due diligence depends on receiving accurate, complete and current information.

Provide accurate information and genuine documents when requested.

Respond reasonably promptly to requests for information required to complete compliance checks.

Tell us about material changes to ownership, control, business activities or other relevant circumstances.

Provide additional information where necessary for us to understand the purpose, source or nature of relevant transactions or activity.

Related policies

This Notice should be read alongside the other policies governing the use of our website and our handling of information.

Privacy Policy How MBS Accounting collects, uses, stores and protects personal information. Terms & Conditions Terms governing access to and use of the MBS Accounting website.

Official guidance

Further information about the UK anti-money-laundering framework is available from official government and law-enforcement sources.

GOV.UK — Accountancy sector AML guidance Government guidance concerning anti-money-laundering responsibilities in the accountancy sector. National Crime Agency — SARs Official information about the UK’s Suspicious Activity Reporting regime.

Changes to this Notice

We may update this Anti-Money Laundering Notice from time to time to reflect changes in legislation, regulatory guidance, our services or our compliance procedures.

The latest public version will be published on this page.