Reply to: Accountant wants credit card details of secretary?!?

[Clare@InTouch]

I'm the sort of person who reads 170 page documents issued by the Board of the Institute of Chartered Accountants of England and Wales (note not Scotland)

http://www.icaew.com/~/media/Files/T...ctor-icaew.pdf

In section 5.49 it lists the evidence that a Chartered Accountant is expected to use to verify ID and I quote them at the end of this post. Note the absence of credit cards and that your company's certificate of incorporation is regarded as strong evidence of ID and although your council tax bill is less strong it is still up there as are bank statements since banks are (badly) regulated by the FSA.

You accountant may not be chartered, but it seems to me that the ICAEW (as its friends call it) says this stuff is kosher, then you can wave it at him.

quote from the ICAEW:

The following are illustrative of a different of strength of various forms of documentary
evidence starting with the highest:

documents issued by a government department or agency or a Court (including
documents filed at Companies House or overseas equivalent)

documents issued by other public sector bodies or local authorities

documents issued by businesses regulated by the Financial Services Authority or overseas equivalent

documents issued by professionals regulated for anti-money laundering
purposesby the bodies listed in Schedule 3 of the 2007 Regulations or overseas equivalents

documents issued by other bodies.

I believe that list is straight from the Money Laundering Regulations as the ICAEW is a monitoring body for AML purposes.

If you're really bored, the whole legislation we base our ID verification procedures around is here:

The Money Laundering Regulations 2007 - Money Laundering Regulations 2007
Proceeds of Crime Act 2002 - Proceeds of Crime Act 2002
The Money Laundering Regulations 2003 - Money Laundering Regulations 2003

Don't forget it's a risk based approach - it's great if someone can supply something from that list, but what if they can't?

[Dominic Connor]

It smells bad

I'm the sort of person who reads 170 page documents issued by the Board of the Institute of Chartered Accountants of England and Wales (note not Scotland)

http://www.icaew.com/~/media/Files/T...ctor-icaew.pdf

In section 5.49 it lists the evidence that a Chartered Accountant is expected to use to verify ID and I quote them at the end of this post. Note the absence of credit cards and that your company's certificate of incorporation is regarded as strong evidence of ID and although your council tax bill is less strong it is still up there as are bank statements since banks are (badly) regulated by the FSA.

You accountant may not be chartered, but it seems to me that the ICAEW (as its friends call it) says this stuff is kosher, then you can wave it at him.

quote from the ICAEW:

The following are illustrative of a different of strength of various forms of documentary
evidence starting with the highest:

documents issued by a government department or agency or a Court (including
documents filed at Companies House or overseas equivalent)

documents issued by other public sector bodies or local authorities

documents issued by businesses regulated by the Financial Services Authority or overseas equivalent

documents issued by professionals regulated for anti-money laundering
purposesby the bodies listed in Schedule 3 of the 2007 Regulations or overseas equivalents

documents issued by other bodies.

[Clare@InTouch]

...but the OP said co. sec. had no dealing with the accountant, so why the interest? My point is, nobody has every asked me to positively identify my co. sec., but then all the correspondance comes through me.

Because the Company Secretary is an officer of the company, and the company is the client (so are the officers in some cases) - in the OP's case they may also be a shareholder, and we have to identify and ID check the beneficial owners of a company before we act.

[Project Monkey]

As Scruff says - plus we have a legal duty to identify the people we do business with to ensure we're not involved with the proceeds of crime, money laundering etc. It lessens the chance that we'll end up with Tony Soprano as a client and inadvertently help him launder drug money through a garbage business - thus making it harder all round for a criminal to launder money through a legit firm.

...but the OP said co. sec. had no dealing with the accountant, so why the interest? My point is, nobody has every asked me to possitively identify my co. sec., but then all the correspondance comes through me.

[Clare@InTouch]

Since there is no longer a requirement for a Company Secretary, I would suggest that the OP access the Companies House website and file a change...

Just a slight word of caution there - if a shareholder wants to claim Entrepreneur's Relief when they sell their shares they have to hold more than 5%, for more than a year, and be an employee or officer of the company (secretary counts for that too).

[Clare@InTouch]

As Scruff says - plus we have a legal duty to identify the people we do business with to ensure we're not involved with the proceeds of crime, money laundering etc. It lessens the chance that we'll end up with Tony Soprano as a client and inadvertently help him launder drug money through a garbage business - thus making it harder all round for a criminal to launder money through a legit firm.

[Scruff]

..all Company Officers (acting in a Fiduciary capacity) are required to be positively identified. There are varying degrees of diligence in complying with this, however.

Since there is no longer a requirement for a Company Secretary, I would suggest that the OP access the Companies House website and file a change...

[Project Monkey]

Please feel free to abuse if this is a stupid question, but why would accountant need to verify ID of company sec. anyway?

[Jessica@WhiteFieldTax]

@Jonson, sorry to hear you are having difficulties. I can't help but think the best approach would be to go back to the accountant with "Why" closely followed by "I'm not comfortable, can you suggest alternative ID".

Using a bank or card for ID isn't uncommon, although its not something we've ever needed to do. Some banks, Cater Allen included as I recall, require (although may not strictly enforce) a private cheque to the company from your personal account as part of the ID process.

I keep my ear to the ground, here and elsewhere, about stuff in the accounting world, and I've never heard of an accountant taking a card for security and starting to debit it with out permission. I'd shudder to think of the multiple s88tstorm from the card company and the regulator (assuming accountants are regulated) if there was a complaint re a unauthorised debit.

And then there's PCIDSS obligations; can't speak for others but our response to that is never to store card details, electronic or manual. So even a client said "charge it to my card to age details" we'd say "No we don't" - Ild imagine we are not alone in that.

[Alan @ BroomeAffinity]

Your accountant is not going to debit you without your knowledge and consent if he is an accredited, qualified and registered accountant.

Darren Upton, anyone?

The OP is right to be sceptical, I guess. But the reasoning holds good I suppose. That should be enough.

You could remove the secretary from the register if it p!sses you off that much. There's no legal requirement to have one.

[borderreiver]

How about asking your accountant for the same credit card and passport information? After all, you need to do your own due diligence as well

[BlasterBates]

Can´t see any problem.

There´s no problem in asking the accountant for other ways to verify, but this isn´t suspicious. It would only be suspicious if it were to be someone pretending to be your accountant. Your accountant, is not going to suddenly start debiting your secretary´s acccount.

If the secretary has a foreign passport then I imagine that would be difficult to verify and the accountant might require further checks.

[Taita]

You have to follow a stricter procedure if the client isn't present though, it's all about risk. A mortgage broker or bank may well meet you face to face, see your passport and check that to your address etc. If your accountant never meets you then you're higher risk, so more proof is necessary if they fail a basic check (for those who move address etc).

There is verification which satisfies the regulations. Then there is over-the-top verification which pedantic idiots apply.... because they can! If the accountant is that worried about the identity of his/her client, they should insist on a personal meeting prior to accepting the client's business.

Nobody is going to jail for not getting credit/debit card details and the bank's rules usually forbid you from passing your details to anybody unless you are entering into a bona fide transaction!

[Scruff]

You no longer require a Company Secretary and do us all a BIG favour - stop playing the race card?

Your accountant is not going to debit you without your knowledge and consent if he is an accredited, qualified and registered accountant.

If you don't have UK Nationality / have not had the same fixed address for more than 3 years, or are on a foreign passport with the correct visa, you will be asked for various types of ID, even if you are a mazungu.

(btw - I am also an Immigrant, from Africa and a Minority).

[Clare@InTouch]

ahhh...I get it...she is from an African country..they can't be trusted right? them foreigners

So white people: 2 pieces of ID

other races: 3 pieces of ID

I was wondering what the **** this was about...there you go....England doing what it does best...behind your back racism

At the risk of sticking my head above the parapet on this one again just to play devil's advocate - has the company secretary been in the UK for the same time as you have, and do they have the same history as you would in regard to previous UK address history? Or could they have failed an ID check due to having moved recently?