Anonymised Anti-Money Laundering (AML) case studies, to assist members in reviewing AML policies and procedures, are available on our enforcement notices page – click here.

Umbrella CMS account operated with direct debit facilities. There was a sub-account for each individual estate, operated subject to Client Money Regs. Could a separate sub-account be used to receive fees (i.e. operated as a firms account) whilst other sub-accounts continued to be operated as Client’s Accounts? There would be no intermingling of funds.

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