AML Checks – Xama HUB

Why checks are required:

As an organisation providing accountancy services ExcluServ is covered by Government Regulations that require a level of due diligence in knowing who we are providing those services for. We have no choice in performing these checks as they are required under government regulations. You will have come across this when dealing with Banks, Solicitors, Estate Agents, and various other professional bodies.

In most cases ExcluServ provides our services to companies and charities, and in this case as well as establishing the legal status of that organisation, we are also required to ensure that we have applied our due diligence to the key officers of that organisation. For Limited companies, this is deemed to be the directors of the company, and for Charities, this is the trustees of the charity together with the CEO or equivalent. Where there is a chair and treasurer of the trustees, these two are the representatives of the Trustee board, against whom we perform the checks. If other members of the board are specifically identified as having a risk attached to them, e.g. being a major donor to the charity or a Politically exposed individual, then they would also be checked within the onboarding process.


Extract from the UK Government Website:

(https://www.gov.uk/guidance/money-laundering-regulations-your-responsibilities)

Money Laundering Regulations

You must meet certain day-to-day responsibilities if your business is covered by the Money Laundering Regulations.

Businesses covered by the regulations

  • The regulations apply to a number of different business sectors, including accountants, financial service businesses, estate agents, and solicitors.
  • Every business covered by the regulations must be monitored by a supervisory authority. Your business may already be supervised, for example, because you’re authorised by the Financial Conduct Authority (FCA) or belong to a professional body like the Law Society.

Responsibilities include

  • Carrying out ‘customer due diligence’ measures to check that your customers are who they say they are,
  • Risk assessing your business with them.
  • You must also put in place internal controls and monitoring systems.

Customer due diligence requirements:

Customer due diligence means

Taking steps to identify your customers and checking they are who they say they are. In practice this means obtaining a customer’s:

  • Name
  • Photograph on an official document which confirms their identity
  • Residential address and date of birth

In practice, the checks involve:

  • Accessing publicly available information about the organisation (e.g. from Companies House)
  • Collecting provided information from the identified individuals (to establish the 3 areas above).
  • If the documents provided do not establish all of the above (e.g. confirmation of Address / DOB) then these might be requested as an additional upload
  • Checking the names of the individuals against international databases to establish if they are Politically Exposed

Privacy and Data Security

In line with our privacy policy, and GDPR best practice, all personal information is collected through the secure portal (Xama HUB) and is held in a secure database that only authorised Excluserv staff have access to.