Accountants and tax
advisors are part of the "regulated sector" (along with other
esteemed professionals including casino operators and estate
agents). That means they are bound by the Money Laundering
Regulations which were revised in December 2007. The rules apply to
anyone providing accountancy or tax services irrespective of
whether they are qualified or not.
The first thing
accountants have to do is carry out something called Customer Due
Diligence. Effectively that means that when you appoint an
accountant he is going to ask you to provide proof of your
identity. He will also want information about your business and
your finances, but he would need that anyway to do your tax work
properly.
Accountants are also
required to make Suspicious Activity reports to SOCA (the Serious
Organised Crime Agency) if in the course of their work they obtain
knowledge or suspicion that someone has committed one of the money
Laundering Offences. These are concealing, disguising, converting
or removing criminal property; entering into an arrangement to help
someone else acquire, retain, use or control criminal property; and
acquiring, using or possessing criminal property
yourself.
The one crime that
accountants are most likely to come across is tax evasion. But if
your accountant believes the information you give him is incomplete
or inaccurate he is going to be challenging you on it
anyway.
The other particular
issue for accountants advising escorts and other prostitutes is
that some of the activities they might be involved in are illegal.
Prostitution itself is not illegal in the UK which means that the
core activity of an escort or a girl simply working in a parlour is
not caught by the money laundering rules.
At the other extreme
managing a brothel is illegal so any income from it is the proceeds
of crime. Any accountant brave enough to act for someone involved
in brothel-keeping needs to take great care particularly where
accounts are prepared describing the income as something
else.