MLR - The first week - How was it for you? [Archive]

neildaws

06-03-04, 01:00

As from 1.3.04 all self-employed members have had to tackle the problems posed by our inclusion in the Government's anti-money laundering (and tax evasion) reporting rules. For me this has meant downloading and studying (a) the Association's Guidelines and (b) the NCIS reporting forms and guides to completion. In addition I studied the CPD video on MLR prepared by the Einstein Network (very good). This latter did raise some questions which I have passed on to the Association for further guidance. I have also obtained the latest versions of Letters of Engagement available from the Association. I then had to set-to and wordprocess them for sole traders, partnerships, limited companies, tax clients and charities. You then have to think about getting all of your systems (identification and reporting etc) into place, and design your internal record keeping procedures. Then you can begin to think about your client base in the context of the reporting requirements. How many reports are you likely to have to file, and how often? How much time is this new system going to take? And, of course, who is going to pay for it? Certainly not the Government. Are there any clients who could be asked to transfer their business eslewhere? And if they do go, what do you say to the new Accountant when you receive the usual professional letter - particularly if he/she asks if you have any concerns in relation to the MLR requirements? And for that matter, if and when you ever decide to take on a new client, have you got the wording right on this subject - and what if you cannot get a satisfactory answer? All of this takes time - bang went the majority of my week in terms of the normal everyday work. I am now working through the Association's ethical guidelines to see if anything there can be of use. Hopefully, some time soon, I will get back to some productive work - and that I suppose is when our problems really begin.