Our Responsibilities and Obligations as Accountants in Confirming Trustee Identities

As accountants, we are legally required to carry out Anti-Money Laundering (AML) checks to ensure that the individuals involved in a charity’s governance, including trustees, are properly identified and that their activities are legitimate.

Our obligations include:

Verifying Trustee Identities

We must confirm the identities of all trustees associated with the charity. This involves collecting and reviewing documentation such as passports, driving licenses, or utility bills to ensure the trustees are who they say they are. This process helps to prevent fraud and ensures that the charity is not being used for money laundering or other illicit activities.

Understanding the Trustee's Background

Beyond just confirming their identity, we must also understand the background and role of the trustees within the charity. This helps assess the potential risk of involvement in money laundering and ensures that the charity is operating with transparency.

Risk Assessment
As part of verifying trustee identities, we also assess the potential risk each trustee may pose. This could involve evaluating factors such as the trustee's history or any connections to high-risk regions or industries.

Ongoing Monitoring
Once the trustees’ identities are verified, we are responsible for monitoring any significant changes to their circumstances. If there are any concerns or suspicions related to their activities, we must reassess the situation and take appropriate action, such as reporting to the relevant authorities.

These checks are essential for ensuring that the charity operates within legal boundaries and that its funds are used appropriately. By confirming the identities of trustees, we help protect the charity from being inadvertently involved in money laundering or other financial crimes.

As part of our AML checks, we ask for copies of photographic ID such as a passport or Driving Licence and a proof of address for all trustees of the charity as well as any persons with significant controls in the charity. We are required to keep a record of the checks. We store all documentation in accordance with the Data Protection 

Applicable Law

Money Laundering Regulations 2017 (MLR 2017)
The MLR 2017 also stipulates that businesses, including accountants, must retain records of customer due diligence (CDD) checks, which include identification documents. These records should be stored securely to prevent unauthorised access and must be readily accessible for inspection by authorities when required.

What Do We Ask For During The AML Check
As part of our AML checks, we ask for copies of photographic ID such as a passport or Driving Licence and a proof of address for all trustees of the charity as well as any persons with significant control in the charity such as CEOs. We are required to keep a record of the checks. We store all documentation in accordance with the Data Protection Act 2018