Callcredit | Compliance | Frequently Asked Questions

Frequently Asked Questions

Welcome to the Callcredit Information Group Credit Solutions compliance area. This area of our site is designed to keep our clients up to date with compliance and legislative issues. Further Callcredit papers on compliance will appear here.

If you require more information on the implications of legislation please contact your Client Manager.

What is money laundering?
What laws are there to prevent money laundering?
What are the JMLSG?
What is the purpose of the JMLSG's Guidance Notes?
What monitoring and supervision is there of this Guidance?
What is required to identify a customer?
What does the JMLSG Money Laundering Regulations require for customer identification?
What is CallML?
How does CallML work?
How easy is CallML to use?
Is CallML fully compliant?
Does CallML provide a PEP check?
Can I check my local customers and remote based customers with CallML?
Can I store a CallML report?
How long do I have to keep my records & CallML reports?

Q1. What is money laundering?

Money Laundering is the way in which criminals disguise the true origin and ownership of the proceeds of their criminal activities so that it appears to come from a legitimate source - thereby changing the proceeds from "dirty" money to "clean". This is performed through a series of transactions.

Q2. What laws are there to prevent money laundering?

The Third Money Laundering Directive was adopted in October 2005 under the UK's Presidency of the European Union. It represents Europe's ongoing commitment to tackle the international problem of money laundering and terrorist financing by implementing the global standards produced by the Financial Action Task Force (FATF) in 2003. Please see the Money Laundering Regulations 2007 for further information.

Q3. What are the JMLSG?

The Joint Money Laundering Steering Group (JMLSG) is made up of the leading UK Trade Associations from the UK regulated sectors. Its aim is to promulgate good practice in countering money laundering and to give practical assistance in interpreting the UK Money Laundering Regulations. This is primarily achieved by the publication of Guidance Notes which were last revised in November 2007.

Q4. What is the purpose of the JMLSG's Guidance Notes?

The purpose of these Guidance Notes is to: outline the requirements of the UK money laundering legislation; provide a practical interpretation of the Money Laundering Regulations 2007; set out the requirements of the FSA Money Laundering Rules, Evidential Provision and Guidance; provide an indication of good generic industry practice and provide a base from which management can develop tailored policies and procedures that are appropriate to their business.

Q5. What monitoring and supervision is there of this Guidance?

The Third Money Laundering Directive sets out the proposed supervisors for each of the regulated sectors, and these have been set to ensure that firms are supervised by the most appropriate professional body. For example, the Office of Fair Trading for Estate Agents, ICAEW for accountants and the Law Society for lawyers.

Q6. What is required to identify a customer?

Money Laundering is the way in which criminals disguise the true origin and ownership of the proceeds of their criminal activities so that it appears to come from a legitimate source - thereby changing the proceeds from "dirty" money to "clean". Criminals may launder money through various means, such as the sale and purchase of property or buying and selling goods and antiques.

Q7. What does the JMLSG Guidance Notes require for customer identification?

The revised JMLSG Guidance recognises firms will 'in many situations need to be prepared to accept a range of documents, and they may also wish to employ electronic checks, either on their own or in tandem with documentary evidence'.

The JMLSG Guidance also describe the benefits of a firm in seeking electronic evidence of a customer's identity , either by accessing external electronic databases directly, or through 'independent third party organisations' Specifically, it says 'the site of the electronic footprint in relation to the depth, breadth and quality of data, and the degree of corroboration of the data supplied by the customer, may provide a useful basis for an assessment of the degree of confidence in their identity'. (JMLSG Guidance, Part 1, paragraph 5.3.3.4).

For further information on the JMLSG please see their website: www.jmlsg.org.uk

Q8. What is CallML?

CallML is a Online Money Laundering identification and verification service that provides an instant electronic check to verify the identity of your new customer. It is compliant with the requirements of the Joint Money Laundering Steering Group (JMLSG) Guidance as noted above.

Q9. How does CallML work?

CallML is a specifically designed structured mechanism to meet the Joint Money Laundering Steering Group (JMLSG) requirements to allow you to swiftly and with confidence identify and verify your new customers. It enables users to reach a decision instantly, with confidence and certainty by interrogating a wide range of independent data sources such as Full Electoral Roll, CCJ's, Bankruptcies & Insolvencies, SHARE (Banking & Financial Account Data), Deceased File, CIFAS File, PEP file, Companies House File, FTSE 350 Investors File, etc.

Q10. How easy is CallML to use?

CallML is very simple to use, as an online service it allows you to input the salient details of your customer. i.e. full name, address and DOB. It then provides a detailed CallML report that provides a definitive "pass or refer" result within 5-7 seconds. Paper based documents such as driving licences, passports, national insurance number, bank statements and many more can also be captured and verified by CallML, and added to the report if required.

Q11. Is CallML fully compliant?

Yes, CallML is designed around the prescriptive requirements for a electronic verification system as detailed in the Joint Money Laundering Steering Groups (JMLSG) Guidance Notes. CallML is widely used by hundred's of organisations and firms who are captured by the 2007 Money Laundering Regulations, and the use of electronic verification on a risk based approach is recognised by the FSA, Law Society, and Institute of Chartered Accountants England and Wales.

Q12. Does CallML provide a PEP check?

Yes, The Third Money Laundering Directive requires all professional firms and organisations from the UK's regulated sector to complete a Politically Exposed Persons (PEP) check on all new business customers as part of their customer identification procedures. CallML automatically checks each customer's details entered against the Government Politically Exposed Persons (PEP) register and reports back a warning if a match is found.

Q13. Can I check my local customers and remote based customers with CallML?

Yes, CallML has been designed as an online system to meet and support the Joint Money Laundering Steering Groups (JMLSG) Guidance and your firms "risk based approach". For clients from the local area who can, or prefer to visit your organisation at a local branch, or office, through to clients that are dealt with remotely via correspondence, or internet via your organisations website.

Q14. Can I store a CallML report?

Yes, CallML allows you to print a hard copy, or save as a PDF electronic file. Providing full details of the customer's identity and verification status .i.e. "pass or refer", name, address, Date of Birth (DOB), Search Reference Number, Date & Time.

Q15. How long do I have to keep my records & CallML reports?

Chapter 8 of the JMLSG Guidance Part 1 provides the guidance on record retention for customer due diligence documents. Records of identification evidence must be kept for a period of at least five years after the relationship with the customer has ended.

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