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Money Laundering Regulations -

Establishing the identity of our client

In common with all bookkeeping and accountancy practices, we are required to comply with

the Money Laundering Regulations.

The Regulations require that, at the outset of all relationships with every client (whether we

are undertaking a one-off piece of work or a relationship intended to span more than one

piece of work), we must take effective measures to ensure that we have established the

identity of our client. We are required to make enquiries and obtain evidence (1) to

establish the identity of the party beneficially owning any business which instructs us (2) to

ensure that the individual in question is an existing person (i.e. not a sham identity) and that

the identity in question has not been appropriated (eg. a person assuming the identity of

another after stealing his/her passport).

Please note that we are exempted from the need for the enquiries set out below only

where:

(i) another professional firm (e.g. another firm of solicitors or accountants) has verified to us

in writing that they have satisfied themselves of the identity of our client to the extent

required by the Money Laundering Regulations;

(ii) our client is itself subject to the money laundering regulations (e.g. the client is an

investment institution registered with the Financial Conduct Authority or any other Financial

Authority carrying on Investment Business).

In all cases other than those where one of the above exemptions applies, we will be unable

to commence acting until our enquiries have been completed and all requested information

has been supplied.

The enquiries we are required to make and the evidence of identity we are required to

obtain vary depending on whether our client is (a) an individual; (b) a UK company; or (c) a

non-UK company:

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(a) For individual clients (as opposed to corporations) we are required to obtain the

following:-

i. name;

ii. home and business addresses;

iii. date of birth;

iv. place of birth;

v. sight of the original of a current full valid passport or national identity card containing a

photograph of the relevant individual. A clear photocopy of the passport is to be retained by

us. Where the individual is resident overseas and is unable to present the original passport

to us, we require written confirmation from a local solicitor that he has inspected the

original passport and that solicitor must provide a certified copy of the same to us.

(b) For UK corporate clients, as a minimum we are required to obtain the following:-

i. the original or a certified copy of the Certificate of Incorporation or a copy of that

document obtained from the Companies Registry;

ii. evidence that any individual representing the company in its relationship with us has the

necessary authority to do so. Normally, we will be taking instructions from a director and

hence a copy of the resolution appointing that director will be required. No further

verification will be required if the company is:-

A) quoted on the London Stock Exchange or any other recognised UK investment exchange;

B) known to be a subsidiary of such a company; or

C) a private company whose directors are already well known to the firm.

In all other cases, the following further evidence must be obtained by us:-

iii. We are required to verify the identity of all shareholders directly or indirectly owning the

company. This means ascertaining the identity of all individual shareholders and then

carrying out the same verification checks as would apply if those individuals were instructing

us in person. Where any shareholder is itself a company, full money laundering checks must

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be made on that company as if it were instructing us separately. A chain of ownership must

be verified in this way until such time as we have identified and verified the identities of all

individuals beneficially interested in the client company;

iv. We must obtain a copy of the latest annual return and accounts (audited where

applicable).

(c) For non-UK corporate clients

The procedures here are the same as those for a UK company but additionally we are

required to carry out the following further checks:-

i. We are required to establish the identity, obtaining sight of and a copy of the relevant

passports, of each of the directors of the relevant company and of any companies higher up

the chain of ownership leading back to the ultimate private individuals who beneficially own

the client company;

ii. We are required to take active steps to identify so far as practical any individuals who

have significant influence and financial control over the company, even if they are not

directors or shareholders of the company or any of its related group companies;

iii. We are required to establish the identity of any individual purporting to represent the

company (including persons purporting to act pursuant to a power of attorney), and satisfy

ourselves that he has the necessary authority to do so;

iv. We are required to obtain satisfactory evidence presented to satisfy ourselves that the

company has not been, or is not in the process of being, dissolved, struck off, wound up or

terminated. Normally satisfactory evidence will be in the form of an up to date company

search. Typically, with offshore companies, this can only be procured by the client since

many jurisdictions refuse to permit third parties to search against the Companies Register.

Alternatively, it may be possible for us to accept a Certificate of Good Standing from the

relevant national company registry. After you have had an opportunity to consider the

above, we ask that you discuss and review with us the evidence that will be required for

your specific circumstances.

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Date: Friday, 15 May 2015

For acceptance.

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