Verifying Repeat Incorporation Customers – Instructions

BACKGROUND We no longer need to verify ID for companies from repeat incorporation customers who are an accountant or solicitor from a country with robust anti-money laundering regulations and compliance, as long as the company order does not contain address service. We must obtain evidence to satisfy ourselves that the customer is regulated for AML purposes from a country with robust anti-money laundering regulations and compliance to process orders without requesting ID for repeat incorporation customers. In the event that a company order contains an address service, we need to verify the ID and address of shareholders owning over 25% of shares as per normal. In the event that a customer is not regulated and they are using their own address continuously for the registered office and service address of a number of companies they are forming, they must use our Registered Office and Service address as otherwise they will be acting as an unregulated Trust and Company Service Provider, which is illegal, and we will not be able to continue processing orders for them. PROCESS Compliance to identify that the company order is from a Repeat Incorporation Customer – i.e. a customer who has formed at least 6 companies, but has less than 7 active address services with us. Compliance to write ‘Paused order – DO NOT PROCEED’ in the MLC Review notes field. Compliance to find the company in the Review section and Pause the order. Compliance will contact the customer by telephone and email to ascertain if the Repeat Customer is a member of an AML regulated body, and if so, obtain the relevant information. If Compliance verifies the customer is regulated Sammy will reply in the Teams Channel – ‘COMPANY NAME – ACCOUNTANT/SOLICITOR VERIFIED AS REGULATED – proceed with order -> Sammy should locate the MLC Review section and write ‘ACCOUNTANT/SOLICITOR VERIFIED – no ID required’ -> Compliance should then unpause the order and submit it to the review stage. If Compliance cannot get hold of the customer to verify the customer is regulated, the order should be cancelled and refunded. If Compliance receives confirmation that the customer is not regulated, they should check whether the customer is using their own address to register all their companies. If they are, this is illegal as they will be acting as a Trust and Company Service Provider and must be regulated by HMRC for Anti-Money Laundering purposes to do so. Compliance  should inform them of this, inform them that they can purchase our address services to get around this issue, otherwise we will no longer be able to process their order. EMAIL TEMPLATE Dear Customer, Proof of AML (Anti-Money Laundering) regulation required to process current and future orders. Thank you so much for the order you have recently placed with us – COMPANY NAME Due to the highly strict nature of regulations governing our business sector, we now require verification as to whether you are an Anti-Money Laundering (AML) regulated agent, either in the UK, EU, or other. Without this information we will need to pause your company order(s). Therefore, to allow us to continue providing you an efficient and timely service, could I please kindly ask you to provide the necessary information requested below. Please be advised the information has to be submitted within 7 days of this request, otherwise regrettably we may need to cancel your order(s). Please answer the following questions with YES or NO Question 1: Are you a UK AML regulated firm acting on behalf of your client? – YES/NO If NO, please answer Question 2 – if YES, move on to ‘If you are a UK AML regulated firm’ section below: Question 2: Are you an AML regulated firm from outside of the UK acting on behalf of your client? – YES/NO If you are a UK AML regulated firm Please provide the following evidence to confirm you are a UK AML regulated firm: Regulated body name: Regulated reference number:  Attach a screenshot of your company or appointed person appearing on the regulated body register If you are an AML regulated firm from outside of the UK Please provide the following evidence to confirm you are an AML regulated firm: Country of regulation: Regulated body name: Regulated reference number: Attach a screenshot of your company or appointed person appearing on the regulated body register Once we have this information, we will be able to process your company order(s). May I thank you for your very valued custom and should you have any queries, please do not hesitate to contact me on phone number.  Kind regards,   Regulatory body registers The company must satisfy itself with screenshot evidence filed away, that a customer is a member of a regulatory body with anti-money laundering regulatory requirements from HMRC. The customer can either take a PDF screenshot of their membership of the accountancy or solicitor’s regulatory body and send it to you, or they can provide you with the name of the body, country of the body, name of the person regulated, to allow you to search for them on the appropriate register.   HMRC AML register https://customs.hmrc.gov.uk/msbregister/checkTerms.do UK Accountancy registers ICAEW – Institute of Chartered Accountants in England and Wales: https://find.icaew.com/ ICAS – Institute of Chartered Accountants of Scotland: https://www.icas.com/find-a-ca-main ACCA – Association of Chartered Certified Accountants: https://www.accaglobal.com/uk/en/member/find-an-accountant/directory-of-member.html CIMA – Chartered Institute of Management Accountants: https://www.cimaglobal.com/About-us/Find-a-CIMA-Accountant/ CIPFA – Chartered Institute of Public Finance and Accountancy: https://www.cipfa.org/members/members-directory UK Solicitors’ Register Solicitors’ Regulation Authority: https://www.sra.org.uk/consumers/register/