Contents

  1. Introduction to the anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy
  2. Regulatory framework – scope of policy
  3. Responsibilities
  4. Anti-money laundering
  5. Expectations
  6. Reporting fraud, bribery and corruption
  7. Client identification procedure
  8. Record keeping procedures
  9. Risk assessment, management and internal control
  10. Gifts and hospitality
  11. Proactive anti-fraud initiatives
  12. Raising concerns (whistleblowing)
  13. Annex1 – Bexley’s procedural and regulatory framework
  14. Annex2 - statutory framework
  15. Annex3 - London Borough of Bexley - code of conduct
  16. Annex4 - anti-fraud, anti-bribery, anti-money laundering and anti-corruption policy

7. Client identification procedure

Where the Council is carrying out relevant and regulated business (accountancy, audit and certain legal services) and: 

  1. forms an ongoing business relationship with a client
  2. undertakes an occasional transaction amounting to 15,000 Euro (approximately £13,000) or more whether carried out in a single operation or several linked ones
  3. suspects money laundering or terrorist financing
  4. doubts the veracity or adequacy of information previously obtained for the purposes of client identification or verification

Then customer due diligence (CDD) measures must be applied and this CDD Procedure must be followed before the establishment of the relationship or carrying out of the transaction. Where CDD is required then evidence of identity must be sought.

Each team of the Council/subsidiary company conducting regulated business must monitor, on an ongoing basis, their business relationships in terms of scrutinising transactions undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions are consistent with their knowledge of the client, its business and risk profile.

In all cases, the evidence should be retained for at least 5 (five) years from the end of the business relationship or one-off transaction(s).