Anti money laundering legislation

All accountants must comply with onerous duties imposed by the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering Regulations 2007 (the “Anti Money Laundering Legislation”), which are intended to inhibit the activities of terrorists and other criminals by denying them access to technical expertise. If we fail to perform these duties, we risk imprisonment. Before we accept your instructions, we may need to obtain ‘satisfactory evidence’ to confirm your identity. In certain circumstances, we may need to obtain evidence confirming the identities of third parties, the source of any funds or other property, the purpose of any instructions or any other matter. We may also need to obtain such evidence after we have begun to act on your instructions. We assume that our clients are honest and law abiding. However, if at any time, there appear to be grounds to suspect (even if we do not actually suspect) that your instructions relate to ‘criminal property’, we are obliged to make a report to the SOCA (Serious Organised Crime Agency), but we are prohibited from telling you that we have done so.

In such circumstances, we must not act on your instructions without consent from SOCA . If SOCA do not refuse consent within 7 working days we may continue to act. If SOCA issue a refusal within that time, we must not act for a further 31 days from the date of the refusal

‘Criminal property’ is property in any legal form, whether money, real property, rights or any benefit derived from criminal activity. It does not matter who carried out the criminal activity or how removed the property is from the original crime. Even if you are honest in your dealings, if your property represents a benefit from someone else’s crime, we must still make a report.

Activity is considered ‘criminal’ if it is a crime under UK law, no matter how trivial, and whether carried out in the UK or abroad. For example, tax evasion is a criminal offence but an honest mistake is not.

Our money laundering Policy

Our policy is to encourage all clients to meet up and discuss their needs with us in person. This gives an opportunity to obtain ‘satisfactory evidence’ to confirm identity. In certain circumstances, we may need to obtain evidence confirming the identities of third parties, the source of any funds or other property, the purpose of any instructions or any other matter. We may also need to obtain such evidence after we have begun to act on your instructions. In all situations we request the sight of current bank account statements and evidence of savings interest received with banks and building societies. If there are transfers from the current accounts to other bank accounts held by the client we would request sight of these too. If a client prefers or decides to withhold this opportunity to allow us to review their bank account statements then we would indicate this on the New Client Form as to the reason.

Details can be obtained from current drivers license and passport or any other document that holds current address such as utility bill. Evidence is preferred to be up to date and if of utility nature (telephone bill etc) within 6 months old. The details taken are reference/account numbers on these documents which are stored on the new client form whilst the client is in the meeting. The client can then read through the form and confirm the details are correct. Clients are then asked to sign and verify this before leaving the meeting. A statement is placed on the document to assure, the client, that data protection regulations are applied where necessary and that any further details and instructions will need a further consultation to agree any further fees that may apply which were not discussed at the time of signing. The engagement letter is then issued for signing and if required by the client, returned on a different day to ensure that clients have had time to absorb and consider our terms of business


It is our normal practice to request clients join a Plan to pay a proportion or all their fees on a monthly direct debit. The Plan will be an inclusive arrangement whereby work will be carried out for you during the whole month that the Plan fees have been paid and any work agreed in this Engagement letter or new client form and any subsequent agreements, with the Plan amount altered accordingly with your approval. These plans are prepayments of work to be done and can be stopped at any time and will be considered stopped at any time if the plan is unpaid within the month end it was intended. This plan is a contract for work for the month its is prepaid for and as such the contract ends for that month and is considered a monthly contract for work carried out. Any plan will be subject to review annually with the possibility to increase at a minimum rate of 4%. If not mentioned within the engagement letter or other agreement signed then the start date is with immediate effect from the date of first payment, as long as there is a minimum of 6 months until the regulatory submission date for the tax document or accounts to be submitted to the authorities included in this plan, or 6 months has passed from the beginning of the plan meaning 6 monthly plan amounts have been paid, then a submission can be made as part of the plan and within this time full support all the time monthly payments are paid is available.


All adhoc Invoices are due for payment 14 days after Invoice date, unless payment by plan of which invoices become due immediately by Direct Debit per plan sign up. Late payment interest will be applied to your account immediately after 14 days at the rate of up 20% of the balance due and after 30 days the amount will be referred to Daniels Silverman Ltd and will be subject to a surcharge of 15% plus vat to cover the collection costs incurred. This surcharge together with all other charges and legal fees incurred will be the responsibility of the customer and will be legally enforceable. Interest will be charged on all overdue debts at the statutory interest rate. For contracts dated on or after 7th August 2002 the late payment interest rate is 8% plus the reference rate. The current reference rate PLUS interest rate for the period from 1st January 2021 is 8.1%. Interest is calculated annually and added daily. For online payment & bill payment: Sort code 09 06 66 account No.41736490 include your company name and invoice number as reference. If you wish to set up Direct Debit please call us on 01206 503157. A new direct debit instruction will take 10 working days for collection.

New clients

It is customary for new clients to agree to a Plan or pay a non-refundable deposit which will be considered payment on account of work to be carried out. This deposit is usually agreed as 50 % of the estimated initial work to be carried out or £50 whichever the lower. Work would not normally be started upon until funds are cleared, AML due diligence has been carried out. No online submissions will be submitted until final invoices or plans are up to date and not beyond the month intended to be paid up.