Onboard two new clients and verify identity

What is going on

Two new enquiries arrived on Friday. The first is a sole trader electrician who wants monthly bookkeeping and quarterly activity statements and has brought his driver licence and a rates notice. The second is Kestrel Imports, a company with a shareholder overseas and a cash-heavy retail store, whose director has provided a company register extract but did not want to give beneficial owner details over the phone and asked whether the firm's trust account could receive a customer payment. Six staff are overdue for anti-money laundering refresher training. The Compliance Manager is available for referrals.

Your brief

Onboard both clients using the Client Onboarding and Identification Form and the Anti-Money Laundering and Counter-Terrorism Financing Policy: verify identity, identify beneficial owners, assign risk ratings, enter both in the Client Register, prepare an engagement letter for the electrician and refer Kestrel Imports for enhanced due diligence with a clear written note of your concerns.

Work through it

You do not need to do it all. Doing a few of these will show you what the work is like. Your ticks and notes stay on this device.

• Read the Anti-Money Laundering and Counter-Terrorism Financing Policy and the Client Onboarding and Identification Form and list the verification steps for an individual and for a company.
• Complete the onboarding form for the electrician, record the identity documents sighted, assign a risk rating and provide the privacy collection notice.
• Enter the electrician in the Client Register with the relationship owner and services and draft the Engagement Letter Template for bookkeeping and activity statements.
• Complete the onboarding form for Kestrel Imports as far as the information allows, identifying the beneficial owner information that is missing and why it is required.
• Assess the risk factors for Kestrel Imports, including the overseas shareholder, cash-heavy business, reluctance to disclose and the trust account request, and assign a risk rating.
• Write a referral note to the Compliance Manager setting out the facts, your concerns and what enhanced due diligence you recommend, without alerting the client.
• Update the Client Register entry for Kestrel Imports to Enhanced due diligence and link it to the open compliance register entry.

What someone in this role would produce

• Completed onboarding forms for both clients
• Client Register entries
• Engagement letter for the electrician
• Referral note to the Compliance Manager