I have been approached by a potential client who is resident outside of the United Kingdom to provide tax advice. How can I identify that individual

Question I have been approached by a potential client who is resident outside of the United Kingdom to provide tax advice.  How can I identify that individual?
Answer

Extra care is required in the carrying out of procedures to identify non-resident individuals. The same steps should be carried out as for a resident individual. If the potential client is non-resident in the UK he may provide identification documents which are unfamiliar to the firm. In these circumstances the firm should consider asking a respected firm of accountants or solicitors local to the potential client to assist with the verification of identity. For example where a firm is a member of an international network it may consider asking its network firm in the client's jurisdiction to assist.

The firm should additionally take care where the country of residence of the individual is one whose anti-money laundering regime is not similar to our own. The UK government may from time to time issue advisory notices listing countries with inadequate anti-money laundering strategies and any that have been categorised as having serious deficiencies. These are normally issued following quarterly Financial Action Task Force ("FATF") plenary meetings. Updates are posted on the Joint Money Laundering Steering Group ("JMLSG") website, www.jmlsg.org.uk, and the FSA website, www.fsa.gov.uk.

In all cases it is important to apply professional judgment as to whether sufficient information has been made available to be satisfied as to the identity of the potential client.

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