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Customer Verification Biometric Facial Recognition

New Service – Customer Verification Biometric Facial Recognition

Under COVID-19 social distancing rules, many prospective clients are no longer able to present their documents in person, while sending them through the post brings a whole new set of issues. With continuing restrictions on personal in place to stop the spread of coronavirus means firms that rely on paper-based ID checks are facing huge business disruption.

Not only is it now almost impossible to get to a post office under the new rules, but sending physical documents also risks contamination. And with so many people now working from home, there is the added risk associated with sending sensitive personal data to the home addresses of staff. Continue reading

Coronavirus Update

Good Morning,

Coronavirus Update

Given the developing COVID-19 situation and following the advice from Government to work from home where possible and avoid unnecessary travel and social contact, I would like to reassure you and confirm that whether we are in our office or working from home we are able to continue to offer a full service.

We will be available both by phone and email between 9am to 5pm, our company formations and Smart Search AML verification software are online and will continue to function 24 hours a day.

We are of course for company incorporations and filings, in the hands of Companies House for the time to process the actual form, once they have processed the form our email confirmation with PDF copies will be sent to you as normal. For the physical despatch of hard copy documents, we are looking at print sessions at the office once or twice a week if possible.

For mail forwarding for our Registered office service most Companies House documents are received from them by email on a daily basis so we can continue to forward by email as normal. HMRC documents are always received in hard copy by post so we will as with the hard copy despatch try to turn these around at the office again once or twice a week.

We would like to wish you all good health for you and your staff during these difficult times and assure you we will be available to support your business as normal as possible during the coming months.

Best wishes

Steve O’Neill

Money Laundering (Amendment) Regulations 2019

Money Laundering (Amendment) Regulations 2019

On 10 January 2020 changes to the Government’s Money Laundering Regulations came into force. They update the UK’s AML regime to incorporate international standards set by the Financial Action Task Force (FATF) and to transpose the EU’s 5th Money Laundering Directive. Specific changes to the regulations that may affect your business include the following categories:

New Obliged Entities

  • regulation 11(d) provides an expanded definition of what a tax adviser is, which means anyone who provides support with tax matters will now come under the definition of an accountancy service provider.
  • regulation 13 (3) to (7) defines letting agency businesses.
  • regulation 14 defines what an art market participant is and what a ‘work of art’ is.


Compliance under MLRs

  • regulation 19 means that businesses need to carry out a money laundering risk assessment of new products, business practices, or technologies before they implement them.
  • regulation 20 sets out requirements in respect of business group-wide policies on the sharing of information about customers, customer accounts, and transactions for money laundering/terrorist financing purposes.
  • regulation 24 agents of money service business principals who are delivering the regulated business must receive relevant training from their principals.
  • regulation 26 (7)(b) sets out requirements to ensure individuals convicted of relevant offences do not act in key roles in regulated firms.
  • regulation 27 requires art market participants to apply customer due diligence measures on all transactions of 10,000 euros or more regardless of payment method.


Customer due diligence

  • regulation 27 sets out requirements for relevant persons to apply customer due diligence measures where there is a legal duty under the relevant international tax compliance regulations, or a duty to review information relevant to the risk assessment or beneficial ownership of the customer.
  • regulation 28 sets out requirements for measures to be taken to understand the ownership and control structure of persons, trusts and companies as a customer, and to verify the identity of senior managing officials responsible for managing corporate bodies, particularly when the beneficial owner cannot be identified.
  • regulation 28 sets out circumstances in which information may be regarded as being reliable and independent of the person providing it where it has been obtained by means of an electronic identification process.


Reporting discrepancies to Companies House

  • regulation 30(a) sets out a requirement to check trust and company beneficial ownership registers before establishing a business relationship, and to report any discrepancies found to Companies House.


High-Risk Factors

  • regulation 33 sets out requirements to apply enhanced due diligence, explains what a ‘relevant person’ is, and what ‘being established’ means.
  • regulation 33 extends the factors a responsible person must consider when assessing the risk of money laundering to include whether the customer is third country national applying for residency rights in an EEA state.
  • regulation 33 extends ‘risky’ products to include oil, arms, precious metals and tobacco.


E-money thresholds for customer due diligence (CDD)

  • regulation 38 reduces the threshold for which low risk electronic money products can be exempt from customer due diligence from 250 euros to 150 euros.


Registration with HMRC

regulation 56 explains that money service business and trust or company service businesses who apply to register from 10 January 2020 will not be able to carry out relevant activity until they are registered with HMRC

Christmas Holiday Support

Support over Christmas

We will be closing the office at close of Business on Friday 20 December 2019, we reopen on 2 January 2020. During this period there will not be telephone support. All online platforms will be operating 24 hours per day, for company formations this is subject to Companies House opening times.

Our support team will be available for limited email support for urgent questions or issues during the following times over the Christmas period:

23rd December – 10.00 – 15:00
24th December – 10.00 – 12:00
25th December – Closed
26th December – Closed
27th December – 10:00 – 15:00
30th December – 10:00 – 15:00
31st December – 10:00 – 12:00
1st January – Closed

Please email businesstax@btc-nw.co.uk and we will try to respond as quick as we can. Have a good Christmas break and we will see you all in the new year.

Business Credit Reports Available Through SmartSearch

Some good news about a further expansion to the BTC AML Search service, the SmartSearch search platform now has Business Credit Reports powered by Experian becoming available on 15 July. This is an additional service and as such carries an additional cost to the normal company search, each additional credit report search is priced at £6.50+vat in addition to the normal search cost.  Continue reading

Government Consultation of fifth Money laundering Directive

Fifth Money Laundering Directive

The consultation invites comments, evidence and views from stakeholders. Responses to this consultation will then be used to inform final government decisions on transposition. The government intends that the new provisions will come into force in national law by 10 January 2020, in line with Article 4 of 5MLD. Continue reading

Companies House Down Time

Companies House have advised they will not be processing submissions from 12 noon, Friday the 7th of September until Monday the 10th of September. Same day submissions must be submitted by 12 noon on the 7th of September.

We will still be holding all submissions in this time frame in review and will submit once the service has restarted on Monday, Experience tells us some orders can be lost at Companies House during these periods of maintenance.

GDPR Rollout

E-Filing Software: When Data Anonymisation Begins

We will be rolling out the latest stage of updates to accommodate for GDPR options tonight 24 May 2018. Our system will restart Friday 25th May.

We are obliged under the Money Laundering Regulations to retain records of transactions for a period of five years from ceasing a relationship. Please note that we will not commence the procedure for anonymising any historic data based on our configuration options until 6th June.

Understanding Historical Last Active Date

For historic, old, records the software never used to store the concept of a “Last Active Date” for customers. This means that for some of our longer standing customers we will be back filling this information based on the following assumptions.

First, we will check when the last Order was placed by the customer or invoice raised or payment made, or if not then revert to the last Incorporation date of any companies on their account, or if that does not exist we will then revert to the date the user account was created.

General Data Protection Regulations (GDPR) Policies

General Data Protection Regulations (GDPR)

we would like to bring you up to date with the changes we are making to the system to ensure GDPR compliance.

Our Customers will need to Opt-In to our GDPR policy to allow us to store their data. For a web user customer of the E-Filing company software, you as a user will be asked the new GDPR opt in question when registering or paying for an order. This will appear at the end of the order process below the T&C’s.

If you are a returning user who has previously opted-in, you will not see the question again and if you wish to opt-out you will need to go to the My Account area where you can update your preference.

Every night the E-Filing system will check user accounts that have opted out of GDPR. The system will disable and anonymise the account and all its contents if they are no longer ‘active’. We will identify an ‘active’ customer as follows;

  • Customer has logged in or visited your website as a logged in customer within a five-year timeframe as the prescribed record keeping requirements within the Money Laundering Regulations 2017.
  • Has pending orders, this includes Companies House form filings.
  • Has pending leads still outstanding with a partner.
  • Has active services running, such as a Registered Address service.
  • Has positive account or negative account balance.

For full details of our policies see out full GDPR document in our privacy page.

Christmas Opening Times

Our offices will close at 1.00 pm on Friday 22nd December and re-open on Tuesday 2nd January 2018. BTC online formations and the SmartSearch AML platform will be live and operational 24-7 throughout this period. The office will have a skeleton staff from 27th to 29th December to assist with any customer service queries, this should be done in the first instance by an email enquiry.

Thank you for your business in 2017 we do appreciate it, and we look forward to serving you in 2018.

Steve O’Neill