Be clear about who your client is.
The person corresponding with your firm may be the customer, or may be acting for somebody else. Establish the engagement first, then request evidence from the appropriate people.
For corporate tax work, include company identity and the relevant people in the case. An employee’s identity document does not, on its own, explain the company’s ownership or the authority behind an instruction.
Keep tax context alongside the check results.
Identity and screening answer specific questions. They do not explain the purpose of an arrangement, the underlying business activity or an unusual instruction. Those matters belong in your firm’s assessment of the engagement.
AMLCode’s connected report is intended to support that assessment by bringing the check results together. Follow up inconsistencies before treating onboarding as complete.
Check the scope of your tax services.
HMRC’s accountancy service provider guidance covers tax advice and assistance within its stated scope, including circumstances where another person provides the service on a business’s behalf. The supervision requirements depend on the services you provide and any applicable exemptions.
HMRC: accountancy service provider supervisionDoes screening replace questions about the engagement?
No. It helps identify potential PEP or sanctions matches. Your firm still needs to understand the service being requested and evaluate the circumstances of the relationship.