Accountants are expected to uphold the standards and ethics of the accountancy profession and the Institutes with which they are affiliated and supervised. YES – WE TOO ARE SUPERVISED!
This commitment to professional standards, ongoing regulatory supervision and a formal requirement to continually update and expand our technical knowledge and relevant skillsets ensures that you, as a client, can have confidence in the integrity and ability of the Accountant working with you and your business.
At Angel Business Management Services Limited we feel you should be aware of the main Compliance and Regulatory obligations placed upon us to help you to appreciate the ‘hoops‘ we have to jump through before we can act as your Accountant or Agent and undertake any work on your behalf, and why it can take a while for new clients to be formally taken on and for work to commence.
Angel Business Management Services Limited and Michael Briggs are supervised by the Institute of Financial Accountants, and we are governed by the policies, regulations and by-laws of this body to ensure we meet and maintain the highest professional standards.
Firm Number: 269587
Member Number: 159344
Practising Certificate Number: 12080
We can be selected at any time and without notice for compliance and regulatory audits by our supervising body. Our latest compliance audit was conducted in September 2019 and we are assessed as fully compliant with our obligations.
In recent years the Accountancy Profession has become more heavily regulated by the Government and HMRC in how we take on and monitor our clients. It is now our responsibility to ensure that we have undertaken appropriate steps to:
- Verify your identity and that of any beneficial owners, operational managers and directors as necessary
- Obtain suitable documentary or electronic evidence as necessary to identify you and your business
- Perform anti-money laundering checks and risk assessments as required by law
- Obtain your authorities and consent to act as your Agent and register this consent with HMRC and Companies House
- Monitor clients on an ongoing basis
Meeting these obligations can take some time to complete the process and we hope that you understand that we are legally required to undertake these processes before we can act on your behalf.
Anti Money Laundering Legislation
All Accountancy Service Providers must comply with onerous duties imposed by the Terrorism Act 2000, the Proceeds of Crime Act 2002, the Fraud Act 2006, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (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 (as noted above). In certain circumstances, we may also 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 further evidence after we have begun to act on your instructions and the evidence may include searching by electronic means.
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 National Crime Agency (“NCA”) 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 NCA. If NCA do not refuse consent within 7 working days we may continue to act. If NCA 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 an offence.
Anti Money Laundering Supervision
We are supervised under the Anti Money Laundering Legislation by our regulatory body the Institute of Financial Accountants.