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Company Due Diligence

For Client:

Engagement starting from:

New client money laundering specific risk assessment

Objective

To assess the risk of money laundering and to establish the extent of customer due diligence to be undertaken.

The Client

1. Is the client outside our normal type of client?		NO
2. Is the sector in which the client operates in any way unusual for us?		NO
3. Is there anything unusual regarding the client’s geographic location and their choice of us as accountants / auditors / tax advisors?	Company Business Address and Registered Address: Directors addresses are the following:	NO
4. (Where appropriate) Do we have any concerns as to why we have not been able to physically see the client face to face?		NO
5. Is the client known to be potentially involved in illegal activities?		NO
6. Is the client a politically exposed person?		NO
7. Has the client been in any way obstructive or evasive when asked for information regarding ownership, the business undertaken or any other information we require?		NO

Nature of the assignment

1. Is there any doubt regarding the services the client requires?		NO
2. Are these services outside our normal range of services?		NO
3. Does it appear in any way unexpected for this client to ask us to provide these services?		NO
4. Is there anything unusual regarding the services requested?		NO
5. Is there any reason to believe that the services or products requested lend themselves to money laundering or terrorism financing?		NO
6. Will we be required to handle client money for this client?		NO
7. Are we providing investment, trust or company services for this client? (If so, consider the risk that we may become concerned in an arrangement that facilitates money laundering.)		NO

Organisational Environment

1. Do the activities of the client involve countries where the production of drugs, drug trafficking, corruption or terrorism may be prevalent?		NO
2. Does the client have any links with any non co-operating countries, or jurisdictions with a higher risk of money laundering or terrorist financing, listed on the Financial Action Task Force website?		NO
3. Is money moved about between different accounts, institutions or jurisdictions without apparent reason?		NO
4. Are we aware of any history of loss making transactions that have occurred without a logical explanation?		NO
5. Is there any funding in place that lacks logical explanation?		NO
6. Is this a cash based organisation?		NO
7. Are there concerns as to whether there are genuine reasons for the organisation handling cash?		NO
8. Do items of stock include attractive and portable consumer goods?		NO
9. Does the client have any strategic alliances with other suppliers or customers?		NO
10. Does the client often use temporary staff?		NO

Risk of fraud, theft and error

1. Are there reasons to question the honesty and integrity of the client?		NO
2. Does available information indicate that the personal financial situation of management is threatened by the organisation’s financial performance?		NO
3. (Where appropriate) Does the owner-manager draw no distinction between personal and organisation transactions?		NO
4. Are you aware of any personal financial obligations of management or employees with access to assets susceptible to theft?		NO
5. Are there any adverse relationships (eg. known or anticipated future employment layoffs) between the organisation and employees with access to assets susceptible to theft?		NO
6. Are we aware of any history of fraud, theft or error within the organisation?		NO
7. Are there any adverse characteristics or circumstances (eg. large amounts of cash on hand) which may increase the susceptibility of assets to misappropriation?		NO
8. Are supervisory controls over the organisation lacking?		NO
9. Are there inadequate internal controls over assets susceptible to misappropriation?		NO
10. Is there a disregard for the need for internal control over misappropriation of assets?		NO
11. Do management or staff with access to assets susceptible to theft appear dissatisfied with the entity or its treatment of employees?		NO
12. Does available information indicate that there a significant number of non-routine or non-systematic transactions at the period end?		NO

Laws and regulations

1. Are there any laws and regulations central to the ability of the client to conduct operations?		NO
2. Is the client currently undergoing or anticipating an external investigation eg. by Revenue?		NO
3. Is there a known history of violations of laws and regulations or claims against the client alleging fraud?		NO

A yes answer will normally indicate a possibility of increased risk. Use the comments column or a separate page to explain if this is not the case.

As a result of the above we have decided to undertake enhanced customer due diligence.

New Non-Audit Client Checklist

All Clients	Yes, no or N/A	Comment
1. Has the source of introduction been established?	Yes
2. Has the name of the previous accountant been obtained?	Add accountants name if relevant
3. Have the reasons for changing accountants been explained?	N/A
4. Do we know why the client has chosen our firm?	Yes
5. What services are to be provided to the client?
6. If the client could find the same service notably closer to home, have we recorded the reason for the client choosing our firm?	Yes
7. Are we being asked to complete work that fits in with our normal client base?	Yes
8. Are we aware of any potential conflicts of interest with existing clients?	No
9. Are we dealing with the ultimate client and not an intermediary who is hiding their identity?	Yes
10. Have we written to the previous accountant for all necessary information?	N/a
11. Are there full details of the client and their activities recorded on the file	Yes
12. Have we assessed the integrity of the client? (And as applicable), owners, directors (or equivalent) and management of the organisation	Yes
13. Has adequate customer due diligence been undertaken? Complete the relevant risk assessment and identity checklists	Yes
14. Have we ascertained and recorded the nature of the client, their/its source of funds and economic purpose (as applicable)	Yes
15. If the potential client is in a regulated industry, have we enquired about the relationship with the regulatory authorities?	N/a
16. Have we established whether the client is subject to money laundering regulation in their own right?	Yes
17. Have we documented sufficient knowledge of the client in accordance with our usual procedures for this type of assignment? Ensure that the specific, relevant legislation, regulation and ethical guidance that applies to the work to be performed is documented	Yes
18. Has the client signed or agreed to sign necessary authorisations?	Yes	LOE
19. Have we the necessary skills and resources to act for this client?	Yes
20. Are there any factors that threaten the firm and/or individuals regarding integrity, objectivity and independence? If so, explain any necessary safeguards put in place.	No

New Client Enhanced Due Diligence - Organisation Identity Checklist

Further guidance on suitable identity documents can be found in section C4. Identity procedures should follow a risk-based approach.	Yes, No or N/A	Comment / Ref	Date
1. Has the identity of the organisation itself been established? Eg:	YES
· . through a full company search; or
· . by certified copies taken from original documents evidencing details of incorporation or registration, registered office and a list of directors and shareholders or equivalent.
2. Has evidence of the organisation’s activity been established and agreed as bona fide?	YES
3. Do we fully understand the ownership structure of the organisation?	YES
4. Select individual(s) (eg. directors) and / or entities who exercise significant influence over the organisation and verify their identity using the relevant identity form.	YES
5. Has evidence of the identities of all beneficial owners been obtained?	YES
6. If there are no beneficial owners, have we obtained confirmation of the identity of those individuals who exercise influence and / or have the largest ownership interest in the organisation?	YES
7. Have copies of the relevant supporting documents been taken and filed?	YES
8. Consider the need to obtain MLNO approval of the extent of the verification evidence obtained given the risk associated with this client.	YES
9. Other evidence (list as appropriate):	N/A

Conclusion

Sufficient evidence of the organisation’s identity has been established to comply with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.

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Timestamp

Audit

19th June 2019 9:28 am IST

Company Due Diligence Uploaded by Accountant Online - hello@accountantonline.ie IP 176.61.5.209

19th June 2019 12:12 pm IST