Beneficial owners are unclear or have not been identified

Supporting documents to show the client's establishment (certificate of incorporation/partnership agreement/trust deed etc.) are unclear or have not been identified

Financial records from the client’s previous accountant cannot be obtained and/or the client’s tax affairs are unclear

The Companies Registration Office or other national registries cannot confirm that information provided by the client corresponds with information held on a public register

Key stakeholders are unclear or have not been identified

An adverse media search has discovered areas of concern

It cannot be verified if the client has any significant overseas interests or operations

A risk-based approach has not been taken in relation to sanctions screening

The client is, or has, a Politically Exposed Person (PEP)

Ultimate beneficial owners and/or all directors are unclear or have not been identified

The client a high-net-worth individual (e.g. assets of €1m/£1m or more)

The client or its beneficial owners have attributes known to be frequently used by money launderers or terrorist financiers (e.g. it is unusual or excessively complex given the nature of the company’s business)

Evidence/documents proving source of wealth and funds cannot be provided

The client has not provided proof of identification and proof of address

The client has been evasive or uncooperative (e.g. appeared reluctant to provide ID)

The client is a public administration or a publicly owned enterprise

The client securities are listed on a regulated market

The client is not based within close proximity of your firm (e.g. within 10 miles)

The client is based outside of the UK

The client is associated with a Sanctioned jurisdiction (e.g. the client transacts with customers in sanctioned jurisdictions or has operations or trade with jurisdictions subject to sanctions)

The client is associated with a geographical area that is considered to have weak AML and Terrorist Financing controls

The client will be using your client's money account

You are providing trust or company services for the client (This includes company formation and use of your address for correspondence)

The business relationship between you and the client is not logical and practicable (For example, the size of the firm’s business is proportionate to the accountancy firm The client’s business falls within the accountancy firm's areas of expertise)

It is not clear why the client has come to use your services (e.g. referred by an existing client)

The client is a cash-intensive business

The client deals with high-value goods

The client operates in an industry typically considered high-risk of money laundering or terrorist financing

You have not met the client face-to-face