Anti-money-laundering policy

We are a supervised UK accountancy practice and a Companies House authorised agent. This is what that obliges us to do, and how we do it.

Our status

City Solution (UK) Ltd is supervised for anti-money-laundering purposes by HM Revenue & Customs under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and is registered with Companies House as an Authorised Corporate Service Provider (AP007847), which requires us to verify the identity of the people behind the companies we form and act for. Our nominated officer for money-laundering reporting is Peter Allen, Director.

Client due diligence — every client

• Identity verification of every director and every person owning or controlling 25% or more, using a government-issued photo ID and a live biometric check, to the standard Companies House requires of ACSPs.
• Proof of residential address for each of those people.
• An ownership chart to the ultimate beneficial owners, supported by the registration documents of each entity in the chain.
• A plain description of what the UK company will do, who its customers and suppliers are, where its funds come from and what volumes to expect.
• Sanctions and politically-exposed-person screening on every individual and entity in the chart, at onboarding and continuously thereafter.

Enhanced due diligence

Applied where the client, an owner or a transaction is connected to a high-risk third country on the UK list, where a politically exposed person or family member or close associate is involved, where the structure is complex or unusual for the business described, or where anything we learn does not fit. Enhanced measures include source-of-wealth and source-of-funds evidence, senior approval before acting, and more frequent review.

Ongoing monitoring

We monitor the relationship for as long as it lasts: transactions we see in the bookkeeping against the profile we were given, changes in ownership or activity, and periodic re-verification. We ask questions when things change, and we expect answers.

Reporting

Where we know or suspect money laundering or terrorist financing we are required to report to the National Crime Agency and are prohibited from telling the client that we have done so. We also report discrepancies between what we know and what appears on the Companies House PSC register, as the law requires.

Record keeping

Due-diligence records and transaction records are kept for five years after the end of the business relationship and then deleted, in line with the Regulations and our privacy notice.

Who we decline

• Anyone unwilling to complete identity checks, or whose documents do not add up.
• Structures with bearer shares, undisclosed nominees or ownership that cannot be traced to real people.
• Businesses whose activity is unlawful in the UK or that we cannot understand well enough to explain to a bank.
• Persons or entities subject to UK, UN, EU or US sanctions, or resident in a comprehensively sanctioned jurisdiction.
• Requests for shelf companies, nominee directors or a registered office without an ongoing relationship.

Training and review

All staff complete anti-money-laundering training on joining and annually. This policy and our firm-wide risk assessment are reviewed at least annually and whenever the regulations or our client base change.

This statement is a public summary of the firm’s internal AML policy and procedures, which are available to our supervisor on request. Draft for review by the nominated officer before publication.