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Sam, Accountant
Category: Tax
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I am a Bookkeeper and so have an Anti Money Laundering

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Hi. I am a Bookkeeper and so have an Anti Money Laundering Supervision. As part of the this I am supposed to run through a customer due diligence procedure, which I have not been doing. I do Bookkeeping work for 3 charities, and all 3 organisations are governed by a number of Trustees - one of them have 13 trustees who are spread around the world. Do I need to get ID (generally passport) for all Trustees of these organisations, or should it suffice to get the ID of the direfctors and the Chair of the Boards? I have the addresses and DOB of most Trustees, so is there a way I can get electronic validation of their ID's from these details, and if so, through which company?
JA: Have you talked to a lawyer about this? In which country do you live? If different, which country is your legal question related to?
Customer: I live in the UK. I haven't talked to a lawyer but have been communicating with a supervisor from the HMRC AMLS service - but he is not responding at the moment so was looking for a bit more information. I do not in any way suspect my clients are guilty of any money laundering, but am just trying to tick boxes so I can prove I am operating in a way that will satisfy their expectations of me.
JA: What steps have you taken so far?
Customer: Already answered in my previous message. I suspect this question is better directed at an Accountant rather than lawyer.
JA: Anything else you want the Lawyer to know before I connect you?
Customer: No.

I've been working hard to find a Professional to assist you with your question, but sometimes finding the right Professional can take a little longer than expected.

I wonder whether you're ok with continuing to wait for an answer. If you are, please let me know and I will continue my search. If not, feel free to let me know and I will cancel this question for you.

Thank you!
Customer: replied 1 year ago.
I'm ok ro wait longer. Please refer the question to an Accountant.

Hi, Sam here , one of the UK tax Experts here on Just Answer, thank you for your question and I shall reply shortly

Customer: replied 1 year ago.
Thanks Sam, I look forward to hearing from you.


Yes ideally you need photo ID for all relevant persons for whom you represent so in the position of a trust all trustees must have evidence of a photo ID tax details (even if abroad) and as you are meant to see the person so you can compare them to their photographic ID you may need to engage in a skype call

However as long as you have for the bank account holders - those that handle the withdrawal and deposits of funds then you have sufficient due dilligence on the trust



Customer: replied 1 year ago.
Hi Sam. So are you saying that all that I must have is photo ID of whoever has the bank account authority?
Customer: replied 1 year ago.
Also, do you know of a company that provides electronic verification given a name, address and DOB? I will not be available to call until this afternoon - but messaging is fine.


Yes you mustt have photo ID of the individual or individuals who have access to the banking as they are he ones who could be exposed to laundering



Sam, Accountant
Category: Tax
Satisfied Customers: 16329
Experience: 26 HMRC expertise, PAYE, Self Assessment ,Residency, Rental Income, Capital Gains, CIS ask for Sam Tax
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