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"Source of wealth information" requested

Discuss Brokers, trading, fees, experiences
PeterGray
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Re: "Source of wealth information" requested

#219347

Postby PeterGray » May 3rd, 2019, 5:29 pm

I had to do this once. I replied with a letter outlining in broad terms where my loot had come from, with no documentation and that was the end of the matter.

johnhemming
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Re: "Source of wealth information" requested

#219350

Postby johnhemming » May 3rd, 2019, 5:39 pm

Alaric wrote:I've long thought it was something of an own goal for MPs and peers to approve the money laundering regulations, always assuming they had sufficient sovereignty for parliament to be asked to approve them.

The logic is the identification and prevention of bribery.

I don't quite understand the "sovereignty" reference unless it is a reference to misunderstanding as to how the EU works.

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Re: "Source of wealth information" requested

#219355

Postby Alaric » May 3rd, 2019, 6:00 pm

johnhemming wrote:I don't quite understand the "sovereignty" reference unless it is a reference to misunderstanding as to how the EU works.


Does or did Parliament ever have the power to modify the Money Laundering Regulations?

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Re: "Source of wealth information" requested

#219371

Postby Parky » May 3rd, 2019, 7:15 pm

Alaric wrote:
johnhemming wrote:I don't quite understand the "sovereignty" reference unless it is a reference to misunderstanding as to how the EU works.


Does or did Parliament ever have the power to modify the Money Laundering Regulations?



As I understand it the Money Laundering Regulations are set by the EU. I had a rant to my MP once when I had to get a notarised signature from my daughter who lives in Canada, which caused some expense and a significant delay. He patiently explained that the UK could do nothing about it. Another reason to vote for Brexit, although I don't suppose it would be a high priority issue. In any case, our politicians have a habit of making things more, rather than less difficult and complicated.

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Re: "Source of wealth information" requested

#219378

Postby johnhemming » May 3rd, 2019, 7:58 pm

The Money Laundering Regulations are a Statutory Instrument. The statutory instruments are passed by the UK parliament in order to comply with the directives relating to Money Laundering from the EU.

Quoting from the fifth directive on Money Laundering.
While there have been significant improvements in the adoption and implementation of Financial Action Task Force (FATF) standards and the endorsement of the work of the Organisation for Economic Cooperation and Development on transparency by Member States in recent years, the need to further increase the overall transparency of the economic and financial environment of the Union is clear. The prevention of money laundering and of terrorist financing cannot be effective unless the environment is hostile to criminals seeking shelter for their finances through non-transparent structures. The integrity of the Union financial system is dependent on the transparency of corporate and other legal entities, trusts and similar legal arrangements. This Directive aims not only to detect and investigate money laundering, but also to prevent it from occurring. Enhancing transparency could be a powerful deterrent.


The Financial Action Task Force has these members and observers
https://www.fatf-gafi.org/about/membersandobservers/

The question you need to ask, therefore, is where the principles are set for this and it is clearly somewhere between the EU and FATF.

This strikes me as something where even if we had "no deal" we would still have to follow the same rules. We would lose, however, our influence over how the EU sets its directives relating to this and what it presses for in the FATF and OECD.

In the end, however, the details are implemented by the UK parliament and if there is any gold plating then that happens there.

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Re: "Source of wealth information" requested

#219380

Postby Alaric » May 3rd, 2019, 8:13 pm

johnhemming wrote: We would lose, however, our influence over how the EU sets its directives relating to this and what it presses for in the FATF and OECD.

In the end, however, the details are implemented by the UK parliament and if there is any gold plating then that happens there.


According to your link, the UK is a member of FATF in his own right.

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Re: "Source of wealth information" requested

#219385

Postby johnhemming » May 3rd, 2019, 8:50 pm

Alaric wrote:
johnhemming wrote: We would lose, however, our influence over how the EU sets its directives relating to this and what it presses for in the FATF and OECD.

In the end, however, the details are implemented by the UK parliament and if there is any gold plating then that happens there.


According to your link, the UK is a member of FATF in his own right.

Indeed and it is exactly the same issue as the WTO. These decisions are made by the larger players viz the EU, USA etc. We do not have a veto on decision and have to live with what the others come up with.

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Re: "Source of wealth information" requested

#219560

Postby yyuryyub » May 4th, 2019, 5:59 pm

The real issue for me (and my wife) regarding "details of the origin of the source of wealth" is in the amount and completeness of evidence required, and how much common sense is applied to assessing it.

I see one category of "source of wealth" is Lottery Win. Yes - that would be nice and straightforward, if you can provide the letter from the Lottery provider. For many of us, wealth has been acquired over 30+ years of work, many many medium sized sources. Perhaps I do have paperwork from the 1990s, perhaps not. Most of the companies that I worked for do not exist any more. I think I got rid of a lot of paperwork that was more than 10 years old - but probably did keep some.

My real source of wealth is not what I earned, but what I didn't spend. That will be tricky to prove.

But I'm resigned to collecting together what is most readily available and seeing how it goes.

And I detest being asked to provide so much personal detail with such a bland and untruthful explanation "Making sure your personal detaiuls are up to date helps us to keep your account secure and deter criminals, so we need to confirm that everything we hold for you is correct". Why can't they give a better explanation? Something like "we need to keep the authorities off our backs, so we're going to ask you for masses of very personal data, because it's much easier to pass the buck to our customers than to keep our own house in order".

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Re: "Source of wealth information" requested

#219572

Postby Alaric » May 4th, 2019, 7:00 pm

yyuryyub wrote:The real issue for me (and my wife) regarding "details of the origin of the source of wealth" is in the amount and completeness of evidence required, and how much common sense is applied to assessing it.


How much are they actually asking for? If you did just state that the source of funds was a lottery win, are you being expected to produce the actual notification? If so, I would suggest a complaint, that they are being disproportionate. In the case of a lottery win, you would probably put the funds into a UK bank account, so it should be up to the first institutional recipient to validate this and not the Broker you subsequently use to invest the funds.

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Re: "Source of wealth information" requested

#219606

Postby supremetwo » May 5th, 2019, 2:00 am

yyuryyub wrote:The real issue for me (and my wife) regarding "details of the origin of the source of wealth" is in the amount and completeness of evidence required, and how much common sense is applied to assessing it.

They want to avoid further fines.

https://www.step.org/news/barclays-fine ... ce-failure

(FCA) has fined Barclays Bank GBP 72 million for failing to conduct proper due diligence checks on a group of ultra-high-net-worth clients who used the bank to move GBP 1.88 billion of funds in 2011 –2012.

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Re: "Source of wealth information" requested

#219613

Postby Alaric » May 5th, 2019, 7:58 am

supremetwo wrote:They want to avoid further fines.


That's the Bank rather than the stockbroker. If all the money that reaches a Stockbroker comes from a UK Bank, I believe the regulations can be interpreted that the Bank can be assumed responsible for the diligence.

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Re: "Source of wealth information" requested

#219628

Postby mike » May 5th, 2019, 10:19 am

rhys wrote: Barclays gently inform me that it's important to know that if I "don't provide my proof of wealth, this could lead to restrictions on my account".

yyuryyub wrote: I was told that anyone not responding adequately might have their accounts frozen. So the letter is a sort of ransom demand, to be paid in paperwork.


Many years ago while I was still working, my company had a deposit account with Standard Life, which was taken over by Barclays.

Shortly after the takeover we received a form requesting information from Barclays, which included a request for sales to each country. We didn't keep per country records, only economic area records, so rang Barclays to discuss.

We were told it was a regulatory requirement, and if we didn't provide the details, access to our funds would be restricted.

Naturally, five minutes later, there was only £50 left in the Barclays account as the balance had been transferred from Barclays to our current account !


So it seems they have a bit of form threatening to restrict access to accounts.

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Re: "Source of wealth information" requested

#219640

Postby mc2fool » May 5th, 2019, 11:22 am

yyuryyub wrote:The real issue for me (and my wife) regarding "details of the origin of the source of wealth" is in the amount and completeness of evidence required, and how much common sense is applied to assessing it.

I am a little (just a little) surprised they're doing this given the uproar and negative publicity when SelfTrade did the same in 2014, and more surprised that you (so far at least) seem to be the only one that's reporting being asked this. Of course, possibly the other Barclay's customers here just haven't received their letter yet....

Could you possibly scan in the letter and accompanying forms and put them up somewhere, suitably redacted of course, so we can all see what is being asked?

When SelfTrade did it there were reams of irate postings on the TMF predecessor of this board* and an intensive ad hoc campaign to get the matter into the media, which was ultimately successful as "after customer feedback" (read: being massively slagged off in the press :D) SelfTrade backed down and decided they didn't need to ask for the source of customers' wealth after all. You might find it of interest to compare what SelfTrade did with what Barclays are asking you now.

This google search will get you some of the press reports, https://www.google.com/search?q=selftrade+2014+source+of+wealth+questionnaire, and the first eight minutes or so of this edition of BBC Money Box was all about it (and at least one of the callers is a regular poster here, I'll leave you to guess as to which one ;)), https://www.bbc.co.uk/programmes/b041txvt.

* maybe someone has a link to the TMF threads in the Wayback Machine? I can't find them on a quick look.

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Re: "Source of wealth information" requested

#219698

Postby TahiPanasDua » May 5th, 2019, 7:18 pm

I got the same ill-gotten gains request from Barkers a few days ago and replied promptly with a few supercilious answers on the form. Basically I quoted roughly half the assets and dividends in our joint account with them. I told them I am retired, have no pension or other income and said they only need to check their own records to know where the money came from.

This of course is not what they are asking.

I obviously made no attempt to provide details of where the money came from originally. I worked overseas for 42 years in Malaysia, Hong Kong, Taiwan, Philippines, Slovakia, Romania, Sri Lanka and Hong Kong again. Imagine trying to trace employment salary and other details for all those different lives !!!!!!

I'm hoping this is simply a box ticking exercise for Barkers and that they are only interested in big bucks money launderers

If there is any adverse response from them I will post details here.

TP2 (cheeky sod!)

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Re: "Source of wealth information" requested

#219719

Postby feder1 » May 6th, 2019, 7:41 am

I found this:

https://www.icpac.org.cy/zePortal/WebFi ... Wealth.pdf

I don't know how relevant it is but suggests that Politically Exposed People and those needing Extra Due Diligence may need to reply.

This from the definitions of "source of funds" and "source of wealth".

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Re: "Source of wealth information" requested

#219739

Postby mc2fool » May 6th, 2019, 10:31 am

feder1 wrote:I found this:

https://www.icpac.org.cy/zePortal/WebFi ... Wealth.pdf

I don't know how relevant it is...

.cy is Cyprus

ICPAC, if you go to the English edition of the site's home page, you'll find is the Institute of Certified Public Accountants of Cyprus

and the very first paragraph of the document says, "This guidance note is prepared to assist ICPAC’s members in obtaining a practical and comprehensive approach on establishing the source of funds (SOF) and source of wealth (SOW) of clients. It is primarily based on FATF recommendations and guidance, taking into account the requirements of the Cyprus AML law, the EU AML Directive and ICPAC’s Directive on AML compliance."

So, while there may be some overlap with UK legislation due to the EU AML Directive, I'd suggest looking for UK documentation would be better :D

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Re: "Source of wealth information" requested

#219746

Postby johnhemming » May 6th, 2019, 10:53 am

The general principles are likely to be the same, but each country will have is own laws and regulators so best to look up the uk rules.

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Re: "Source of wealth information" requested

#220354

Postby IR35x » May 9th, 2019, 10:34 am

We have also received the requests. I spoke to my Barclays account manager and he said that all people with more than a certain amount invested with Smart Investor will get the same request. Other than that he didn't have much advice other than to fill in the form - which is not an easy task.

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Re: "Source of wealth information" requested

#220357

Postby fisher » May 9th, 2019, 10:40 am

When I had one of these a few years ago from Selftrade I filled the form in with some rough estimates of the amounts that came from Employment and those that came from other investments and sent it back to them. Once they had registered it in their system I then sent in my transfer forms to transfer all of my stocks from them to another broker as I was put out about the heavy-handedness of their approach to this. I doubt anyone really read the form I sent in anyway - certainly not with much scrutiny if they did.

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Re: "Source of wealth information" requested

#220368

Postby Alaric » May 9th, 2019, 11:10 am

IR35x wrote: I spoke to my Barclays account manager and he said that all people with more than a certain amount invested with Smart Investor will get the same request.


Why not just tell him the the source of funds, other than earnings on the investments, was a UK bank account (assuming that it was) and that he should rely on the compliance of the UK bank? After all, you can move a sizeable portfolio from one UK ISA or dealing account provider to another without being asked where it originally came from.


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