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  • Felicitas Demanding Proof of Your ID & Address?

    17 September 2020

    Alexander Wilson

    Felicitas Demanding Proof of Your ID & Address – Do you need to respond?

    Background – Do you need to respond?

    Many people (often unwittingly) entered into disguised remuneration arrangements by which they received ‘loans’ instead of being paid a salary. Generally, there was an understanding by both sides that these loans would not be repaid.

    It is fair to say that HMRC have taken significant steps to counteract these schemes and have argued that, in substance, these loans were recompense for services rendered and subject to be tax as earned income. The loan charge has been used as a stick to encourage users of the schemes to settle.

    Behind the scenes, as the original promoters have scattered far and wide, many of those ‘loans’ have been sold on to third parties who now claim to be collecting on those loans. Felicitas is one such company. Our clients dispute these debts…

    Felicitas – Requests to Confirm Identification

    Recently, Felicitas has written to our clients (and we know many others) making a request for the client to provide proof of identification and address. The request is very formal and gives the impression that you have a legal requirement to comply, citing Isle of Man Financial Services Authority regulations.

    We have been in direct contact with the IoM FSA. We have confirmation that you are under no obligation to comply with this request.

    Only Felicitas has any legal obligation here.

    Our position is that our clients are under no obligation to comply with this request. Whether you supply any documentation to Felicitas remains a matter of individual choice and one which may be informed by your regard of Felicitas and what goodwill you have toward them.

    Anti-Money Laundering Regulations & Data Security Generally

    For the avoidance of doubt this advice is specific to the Felicitas situation.

    As a regulated business we regard proper anti-money laundering requirements as being a vital weapon against organised crime and we take our responsibilities in the regulated sector with the utmost seriousness. We would not discourage non-compliance with anti-money laundering requirements where they in fact apply.

    You should always be careful with whom you share your personal data. Guidance may be sought from:

    Contact Us

    If you have any queries then please do not hesitate to let us know.


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