From 15 December 2007, the Money Laundering Regulations 2007 came into force, repealing and replacing the Money Laundering Regulations 2003. These new regulations set administrative requirements for the anti-money laundering regime within the regulated sector and outline the scope of customer due diligence.

The Regulations aim to limit the use of professional services for money laundering by requiring professionals to know their clients and monitor the use of their services by clients.

So how does this impact SFS and our services?

The regulations clearly state that the they apply to persons acting in the course of business within the UK for the following areas-

1) credit institutions
2) financial institutions
3) auditors, insolvency practitioners, external accountants and tax advisers
4) independent legal professionals
5) trust or company service providers
6) estate agents
7) high value dealers
8) casinos

This directly affects SFS as a "trust or company service provider” refers to a firm or sole practitioner who by way of business provides any of the following services to other persons—

(a) forming companiesor other legal persons;
(b) acting, or arranging for another person to act—

(i) as a director or secretary of a company;
(ii) as a partner of a partnership; or
(iii) in a similar position in relation to other legal persons;

(c) providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or any other legal person or arrangement;
(d) acting, or arranging for another person to act, as—

(i) a trustee of an express trust or similar legal arrangement; or
(ii) a nominee shareholder for a person other than a company whose securities are listed on a regulated market

As you can see SFS provide the above highlighted services. Therefore it is essential that SFS work within the new regulations and collect identification for clients that we provide services to.

Effective ‘customer due diligence’ measures are an essential part of any system designed to prevent money laundering and are a cornerstone requirement of the Money Laundering Regulations 2007. SFS are responsible for implementing due diligence in the following circumstances-

When establishing a business relationship,
When carrying out an occasional transaction,
Where there is a suspicion of money laundering or terrorist financing; and
Where there are doubts concerning the veracity of previous identification information.

Therefore SFS need to identify any individuals or owners of any company that we establish a business relationship with. This is essentially ‘know your client’ and is applied to all clients that we provide continuous services to.

To better 'know our clients' we may-
Request that a client registration form is completed.
Request copies of a person’s ID (photo driving licence, passport, utility bills, bank statement etc.)
Request that certified copies of these documents are provided.
Request to meet the individuals involved in the business relationship.
Conduct identification checks with a checking agency.

These steps should ensure that we know our clients. However, should we need any further information or identification from you we will contact you to discuss the matter.