Finding alternative processes
HMRC made the move to contact agents after seeing an increased number of queries from about whether Customer Due Diligence checks should go ahead, and how to get them completed.
HMRC recognises that many businesses are facing significant challenges but advises agencies to use procedures in place for Anti Money Laundering (AML) identity checks when the client is not physically present and to make use of these more during social distancing restrictions.
It is still imperative that agents fulfill their obligations under the Money Laundering Regulations (MLRs).
HMRC recommendations for agents
Agents undertaking AML supervised activity should consider:
- how the changed circumstances impact on risks, policies, controls, and procedures
- reviewing the guidance from the Joint Money Laundering Steering Group
- reading the Government’s guidance on identity proofing and verification
- following established processes to meet MLR obligations where an agent cannot be satisfied that the customer or beneficial owner’s identity can be verified, or that the risks associated with a business relationship or transaction can be managed.
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