External accountants: onboarding a new customer

Establish your role first

The obliged entity is the authorised business providing accounting advice, bookkeeping or tax records. Where an accounting company holds the engagement, its employee acts within that company’s system. An employee working directly for the customer is not a separate obliged entity merely because of that accounting work. The customer may nevertheless have its own AML duties arising from a different activity.

The relationship determines the trigger

Identification at establishment of a relationship under section 7(2)(b) applies regardless of value. Due diligence under section 9 follows that regime and continues throughout the relationship. Expected continuity or repetition at inception matters, rather than the contract’s label. Preparing a tax return every year must therefore be assessed before treating it as unrelated occasional transactions.

For an occasional service distinguish identification when value exceeds EUR 1,000 from the further due diligence triggers in section 9. FAÚ’s published interpretation considers the subject matter of the service, rather than just the accountant’s invoice. Record the evidence used and do not automatically apply the threshold to the fee.

Checks before work starts

Obtain information about both the company and the person actually acting for it. Verify the company’s existence, the representative’s authority and their identity using a statutory method. A questionnaire or emailed photograph of an identity document alone does not establish completed identification. For remote work select a specific permitted method and document all its conditions.

Due diligence covers purpose and nature of the service, customer business, beneficial ownership, ownership and management structure, risk and assessment of the origin of the relevant funds or assets. For a registrable beneficial owner, section 9(2)(b) requires the register or equivalent register and another source. Justify additional evidence by risk; do not collect an entire family financial archive without a reason.

The file must show the process

Retain dates, verification methods, sources, unresolved issues and the acceptance decision. Resolve inconsistencies between stated activity and transactions before further performance. Where cooperation is missing apply section 15 and separately assess suspicion. A signed declaration is not automatically sufficient. Receiving files from a former accountant does not remove the new accountant’s responsibility.