The legal framework
We comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the "MLRs"), as amended, and the AAT's Anti-Money Laundering Policies and Procedures Manual. The AAT is one of the UK's designated AML supervisors under the MLRs.
Customer due diligence (CDD)
Before we can act for you we must verify your identity. The standard checks are:
Individuals
- Photo ID — a current passport or photocard driving licence.
- Proof of address dated within the last three months — utility bill, bank statement, council tax letter, or HMRC correspondence.
Limited companies, LLPs, partnerships
- Companies House registration evidence (we pull this directly).
- Photo ID and proof of address for each director, partner and beneficial owner (any person with more than 25% ownership or voting control).
- Where ownership is held through a corporate structure, we'll trace the structure to its ultimate beneficial owners.
Enhanced due diligence (EDD)
We apply enhanced checks if any of the following apply:
- You're a politically exposed person (PEP), or a close associate or family member of one.
- You're based in, or have significant connections to, a high-risk jurisdiction as listed by the Financial Action Task Force (FATF).
- The transaction or business relationship has unusual features inconsistent with what we'd expect for your industry or financial profile.
EDD includes obtaining additional documentation of source of wealth and source of funds, and senior-partner sign-off before we accept the engagement.
Ongoing monitoring
We monitor your activity with us throughout the engagement. If a transaction looks inconsistent with what we know about your business, we'll ask you to explain it. If we have a suspicion of money laundering or terrorist financing that we cannot resolve, we are obliged to file a Suspicious Activity Report with the National Crime Agency — without telling you we've done so ("tipping off" is a criminal offence).
Record retention
We retain CDD records (identity documents, source-of-funds evidence, screening results, risk assessments) for five years after the end of our business relationship with you, in line with the MLRs.
If we decline an engagement
We will decline to act, or terminate an existing engagement, if we cannot complete CDD to our satisfaction, if you provide inconsistent or false information, or if continuing would breach our AML obligations. In some cases the law prevents us from explaining the reason.
Sanctions
We screen new clients and ongoing transactions against the UK, EU, US OFAC and UN sanctions lists. We will not act for any person or entity on those lists.
Reporting concerns
Our Money Laundering Reporting Officer (MLRO) is the practice principal. If you believe we have failed to meet our AML obligations, contact our MLRO at info@thetaxconsultant.co.uk. You can also report concerns to the AAT or directly to the National Crime Agency.
Why this matters to you
We know the document requests can feel intrusive — they're not about distrust, they're about meeting the law. Every UK accountancy practice does this. Once your CDD is complete it won't be repeated unless a material aspect of your circumstances changes.