FAQ and Support

Someone is engaged in Money Laundering if they:

• Conceal, disguise, convert, transfer or remove (from the UK) criminal property;
• Enter into or become concerned in an arrangement which they know or suspects facilitates (by whatever means) the acquisition, retention, use or control of criminal property by or on behalf of another person; or
• Acquire, use or has possession of criminal property

All individuals working for the firms and carrying out 'accountancy services' have a personal legal responsibility to report any knowledge or suspicion of Money Laundering as soon as practical. The maximum penalty for not reporting is five years imprisonment and or an unlimited fine. An employees' duty ends when the report has been made to the Money Laundering Reporting Officer and a receipt has been received.

Where there is no useful information. For example where you are unable to identify the culprit or the whereabouts of criminal property.
Where the crime occurred overseas and was a legal act under the local law.

Online client verification enables users of AMLCC to verify their clients online. The verification tool is provided by Callcredit and is called CallML. This has been designed specifically to comply with the latest anti-money laundering regulations. It is important to realise that some verification tools provided by other companies are not fully compliant with the latest anti-money laundering regulations.
CalML works by interrogating a wide range of independent positive and negative data sources to enable users to reach a decision instantly.

• Simple to use and intuitive
• Quick and easy to adopt
• Uses comprehensive quality data sources
• Speeds up the application process for new clients
• Powerful 'pass' or 'refer' result provides immediate decisioning certainty
• Enables the capture of government issued and other secondary approved documents
• Full audit trail

AMLCC provide access to the latest version of CallML. This latest version has been designed specifically to comply with the latest anti-money laundering regulations. Earlier versions of CallML are not compliant with the latest regulations.
All online client verifications are stored online in the clients' records. You can therefore access these anytime. The verifications also compliment the risk assessment tool which is also provided by AMLCC.
Online client verification is simple and straight forward to use. It is all accessible through the AMLCC website, you don't need to email the clients' details to any other company to carry out the verification for you.

Each verification costs £5 plus VAT. There are no commitment levels and no set up fees. It is simply provided on a pay as you go basis. Payment is made through the AMLCC website.
It is important to point out that the version of CallML which AMLCC offer is fully compliant with the latest Money Laundering Regulations, this will not be the case for other products on the market.

You will have to advise your client that you intend to carry out an online verification on them. However, you do not need their permission as it is a legal obligation that you do one and they are not allowed to refuse.

Yes, the version of CallML which AMLCC offer was released to comply with the 2007 Money Laundering Regulations and the 2007 released JMLSG guidance required to support the implementation of the 3rd ML Directive. This version release has number of significant changes to meet these new stringent requirements
Earlier versions of CallML are not compliant with the latest regulations.

Up until the 2007 Regulations this could have been considered to be adequate. From the 15th of December 2007 regulated firms are required to implement a Risk Based Approach to Customer Due Diligence.
Photocopying documents is still acceptable as long as you also have policies and procedures that determine whether a customer is a Politically Exposed Persons'.
CallML checks this register along with the Bank of England Sanctions list and OFAC.

No. It is the obligation of your firm to implement Risk based Anti Money Laundering Customer Due Diligence Procedures - not your clients.

CallML verifies against a customer's constantly expanding and comprehensive range of data sets, including:

Positive Data:
• The full Electoral Roll
• SHARE information
• County Court Judgements
• Bankruptcies,
• Administrative Orders & Insolvencies
• The Investors Dataset
• Directors At Home
• Date of Birth confirms
• Post Office Address File

Negative Screening:
• HM Treasury
• Sanctions List
• Politically Exposed Persons File
• Specially Designated Nationals File
• Gone Away Suppression File
• Forwarding Address links
• Non-Standard Address File
• Deceased Indicators
• CIFAS Flags

Warning Messages:
• Residency < 12 months
• Non Standard Address
• Lost / Stolen Passport (reported to CIFAS)
• Mailsort Code Mismatch
• Driving Licence Algorithm
• Global Passport Validation
• Date of Birth Conflict

Yes, as a user of our services you are required to be registered under the Act. Registration is extremely simple and can be done at
www.ico.gov.uk

Identification of a individual client is a two way process. Accountants first need to identify the client by obtaining a range of information such as their name, address and DOB etc. The second part is verifying this information through the use of reliable and independent sources. This evidence can take a number of forms and can be documentary (passport, driving licence), electronic (online client verifications) or a combination of both'.

How much evidence to ask for in order to be reasonably satisfied as to a clients identify is for the accountant to decide based on their risk-based identification and verification procedures.

The online verification tool which is available through AMLCC is provided by Callcredit. This has been designed specifically to comply with the latest anti money-laundering legislation and does away with the need for documentation. Electronic resources are now considered an acceptable part of the client verification whereas this issue was not addressed in the previous guidance.

The data sets searched include, electoral roll, all bank accounts, credit cards, mortgages, loans etc (all shared with the financial services industry), CCJ's, IVA's & insolvencies, FTSE 350 shareholding, directors at home, PAF, deceased persons files, stolen passports lists, PEP and sanctions files, previous searches and more. They are fully equipped for the rigors of the ML Regs 2007 including risk assessment.

CallML works by interrogating a wide range of independent positive and negative data sources to enable users to reach a decision instantly. An additional requirement of the MLR2007 is to check all clients identified as high risk against the Politically Exposed Persons register and other sanctions lists, this is done through the online verifications.

However the use of electronic verification only confirms the existence of a person, not that your client is that person. In accordance with the risk sensitive approach, for higher risk persons, you may wish to obtain additional verification evidence or remain alert to evidence that might suggest that they may not be who they say they are (i.e. they ask you to send the engagement letter or correspondence to another address).

In summary therefore for low risk clients you will be compliant with the verification requirements of the regulations if you carry out an online verification. For high risk clients you may also need to do additional checks. By carrying out an online verification check and say obtaining a copy of a passport and driving licence you are effectively carrying out identification evidence which would be required for 'high risk' clients. This 'belt and braces' approach would therefore ensure compliance for all clients irrespectively of their risk assessment.

However it should be stressed that the initial confirmation of the client's ID is only part of the Money Laundering Regulations 2007, there is a lot more required to comply with the Customer Due Diligence requirements.

All Accountancy Service Providers (ASP) and Trust and Company Service Providers (TCSP) are required to comply with the Money Laundering Regulations (MLR 2007). Unfortunately these are not specific in a number of areas resulting in a considerable volume of other guidance that, as it is approved by HM Treasury, is effectively included in the compliance requirements for all ASPs. This includes two documents issued by HMRC (MLR8 and MLR9) and the documents produced by CCAB for the accountancy organisations with a further guidance note prepared by Association of Taxation Technicians.

We developed the AMLCC product to provide, what we believe to be, a complete guide for accountants to assist with their compliance with the Anti-Money Laundering Regulations.

As you may be aware the product includes a risk assessment wizard that can be applied to all client types. This basically includes the questions that you should be asking of all your clients to determine the level of risk that each client presents. This is a requirement of the MLR2007 regarding due diligence.

The online client verification tool is provided by Call Credit and is approved by HM Treasury for verifying the client's identity. The training module has been written to offer sufficient training to MLRO and staff and covers the subject thoroughly, including in the 2009 version, a summary of what to expect when your Supervisors Inspector calls. There is a separate training video for the MLRO and staff and included is a test for which all staff must achieve a pass mark. Asking the MLRO and staff to carry out the training will demonstrate to the relevant Supervisory bodies that you have trained your MLRO and staff in accordance with the MLR 2007 requirements. There is no specific guidance on what is acceptable training but it must be renewed at regular intervals.

We have also written a hard copy manual includes detailed documentary evidence of policies and procures as advised in the CCAB Guidance. It is therefore good practice for ASPs to have a compliance manual including the required documentation.

It is also important for all staff to make an internal report to the MLRO should they have suspicion that a ML offence has taken place. We have created functionality within the product to make this procedure as user friendly as possible. All staff can make an internal report to the MLRO by completing an simple, straight forward online form. This is sent automatically to the MLRO who will then be alerted to the filed report the next time he logs in. He will have to acknowledge to the member of staff that he has indeed received that report.

AMLCC is not able to provide a guarantee that the product will totally exempt subscribers from any compliance issues should they be inspected by their Supervisory Organisation. Although the supervisors will follow the CCAB and ATT Guidance in applying the MLR, there will inevitably be slight differences in their approach and indeed the obligations placed upon their member. However we feel that our product is sufficiently comprehensive to demonstrate to the Supervisory Organisations that AMLCC subscribers, who use the product to its full capacity, have taken all reasonable steps to comply with the legislation.

Whilst we have taken every care to ensure that our product will enable our subscribers to comply with the MLR, it is the responsibility of firms to study the MLR and authorised documents to ensure their compliance and also to follow the guidance provided by their supervising authority.