AML Process 

Anti-Money Laundering (AML) and ‘Know Your Customer (KYC) Requirements

Money Laundering is the practice of converting the proceeds of crime into legitimate funds and as part of a global effort to stop these crimes, the UK has enacted the Money laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (hereafter known as the Money Laundering Regulations 2017).

The Act regulates various UK financial institutions and business advisors, by making them responsible for knowing who their customers are. Regulated businesses must complete due diligence checks on their customers. Company Formation Agents are regulated by the MLR Act and fall under the category of “Trust or Company Service Providers”.

This document sets out the processes which are undertaken for the due diligence and risk assessment requirements as per our business’s risk assessment.

Who is being checked? 

Every formation that is submitted through our website must undergo an AML check prior to submitting the application to Companies House. We work with the following queues:

1. UK queue
   
2. Non UK queue
   
3. On behalf of queue – AML check done every 12 months
   
4. Check and Send queue
   

And also perform an AML check in the following situations:

1. RA new subscription outside of the filing flow
   
2. RA change of forwarding address
   
3. Adding a director/shareholder/PSC to the company (applies to RA and non-RA cases) - prior consent from the current PSC has to be obtained
   

Below are the reason codes in the AML queue that you can come across:

1. AML is required for all formations – Customer has not purchased any additional products 
   
2. Business is forming on behalf of someone else, AML report is not expired but we need to check business owners, so will require an AML check. – Refers to anyone choosing the ‘submitting on behalf of someone else’ option in the filing flow – AML check to be completed every 12 months
   
3. Business is using a registered/service office or mail forwarding product, so will require an AML check. – Customer has purchased our RA service
   
4. Business purchased the check and send service – On top of an AML check we will also need to complete the Check and Send process
   

NOTE: You can find a combination of reason codes, I.e. customer it forming on behalf of someone and has purchased the Check and Send service, so please pay close attention to it. 

What system is used to run the AML check? 

The main system we are using to do our AML checks is Cross Core but we still use our provider Smart Search as backup for UK searches as well as our main tool to complete International ID checks for our non UK customers. 

The data is put into the SmartSearch/Cross Core system automatically from the filing flow data set; the data set is taken from the AML screen on the TFC Admin system. The data which is uploaded is as follows:

1. Full Names
   
2. Full Residential Address
   
3. Full Date of Birth details supplied
   

However, the AML queue still gives us access to the customer’s ID document number and expiry date as well as the possibility to view the document that was uploaded. 

AML queues and search function explained

The primary system to use is Cross Core and it can be accessed as shown on the screen shot below:

Once Cross Core has been selected you can now navigate between the different queues:

We are actively working with the following sections:

Awaiting Action

1. UK residents
   
2. Non-UK residents
   
3. Awaiting further docs
   

Check and Send

Before you run the actual AML search you will have to check that the ID document that was uploaded by the customer is correct and matches the information entered in the filing flow. 

As the passport/DL data check is only an algorithm check and not a data verification check this will allow you to spot the following error before having to run an AML check:

1. Does the name/DOB on application and the ID match?
   
2. Has the correct ID been uploaded? The application states that either a passport (UK or international) or a full UK Driving License needs to be uploaded. 
   
3. If a Full UK Driving License was uploaded, does the address match the residential address entered on the application? FIY - It is a legal requirement (and a fine for up to £1000 can be imposed for failing to comply) to have the up-to-date address on your Driving license, however, we find that a lot of our customers have not complied with this.
   

NOTE: In this instance, do not run the AML check and request further POA, making the customer aware of the mismatch and requesting further explanation on this. Once POA is received, run the AML check and if it passes approve the application and point out to the customer that they need to update the address on the Driving License 

1. Provisional Driving License: If the customer uses a provisional license but the address on the application matches the address on the ID document, run the AML check and pass the application (based on positive result). Should there be an address mismatch, do not run the AML and proceed by requesting a further POA and PID
   
2. Has a different type of ID been uploaded?
   
3. Is the picture clear/does it show all relevant details, especially the MRZ number at the bottom? 
   

Once you have verified that everything meets our criteria, you can then proceed to run the AML check. This is done by clicking on the ‘search again’ section towards the bottom of that individual search

NOTE: The same process applies if you were to run the AML check via Smart Search. Only difference is that Smart Search does not allow a document preview (view scanned document) so it is recommended to the preliminary checks first via Cross Core and then to proceed to Smart Search.

Once you have run the search you can take the following 3 actions depending on the outcome:

If the AML check passes, add a note to say it was approved and click Approve.

If the AML fails and you are going back to the customer to request further documents, then add a note of what the result was and what it is you are requesting and move the application to awaiting further documentation. Also, in the next step once the customer returns the requested documents and you are able to approve the application, remember to add the Zoho ticket number in the note section in the AML queue. 

NOTE: We do not currently move Check & Send and on behalf of applications (where the AML representative fails) into awaiting further documentation. These applications remain in the current queue with a relevant note added.

If you need to make any changes to the application, you can press Reject and that will allow you to masquerade into the account and edit the application as required.

Result interpretation

Cross Core 

After you click on the ‘search again’ button via Cross Core the page will refresh so copy the company name you are doing the AML check for. At the top of the page, you will now see the result of your search and this will look as follows:

Please refer to the document below for an explanation on what the results codes stand for – tab High Risk Alerts:

AML = High Risk Alerts

In general, you are looking at the following result interpretation:

1. Authenticated = Pass
   
2. Refer = Refer
   
3. Not Authenticated = Fail 
   

If the result is a Pass the following screen will present.

In the ‘messages’ section the rule ID will confirm that the identity has been confirmed at the required level. If that is the case, you can simply ‘download’ the file and save to the following location: 

X:\The Formations Company\Customer Service Team\London City Office\TFC – AML

You can now add a note to the note section, save the note and then approve the application

If the result is Refer you will most likely be presented with one of the following scenarios:

To review the PEP process on Smart Search please go to section 5a) 

If the result is Fail, you will be presented with the following scenarios:

Result: The identity supplied has NOT been confirmed AT ANY required level

Action: Request POA, if address is as entered on application request additional ID

Result: The identity supplied has NOT been confirmed AT ANY required level

AND Rule U000 No trace of supplied Address(es)

Action: Request ID & POA

Send the further documents required email, add a note in the note section in the AML queue and move the application to awaiting further docs (unless you are in the on behalf of queue).

Smart Search 

As mentioned above, Smart Search AML checks can still be run at this point but should only be used if all options on Cross Core have been exhausted. You would simply need to switch to the Smart Search section on TFC

How you process the AML check is the same as on Cross Core – Click on ‘Search Again’. Unlike Cross Core however, the result is either Pass or Refer.

If the AML check passes, the result will looks as follows:

You will need to download and view the document as Smart Search may pass the person on the address but only by viewing the document you will identify if the person is a possible PEP/on Sanctions list.

These are the sections you are looking at on the Smart Search report:

The number of primary checks will need to be at least 3. If any lower the result would have been ‘refer’. 

The above shows the matches that are found against that person’s name and address and confirms if the passport number entered follows the correct algorithm. 

It is very unlikely for a customer to score 0 whilst all details being entered correctly (unless there is some fraudulent activity). There is usually an error somewhere. So again, carefully review the application to spot anything that was entered incorrectly but should the result hold up then follow the steps below:

1. contact customer to advise their AML check failed
   
2. cancel application and refund
   

How to request further documents through Zoho Desk

Further documents emails are sent via Desk. You can simply create a ticket through TFC or LZ and by selecting ‘Admin’ as category, ‘AML’ as sub category and ‘Awaiting further Docs’ as reason it will prompt you to enter the company’s name and the shareholders’ names.

Once you have entered this information, use the drop down in the ‘Send Communication’ category and select the relevant template. By submitting the ticket, the email will be sent automatically. Should you need to make further amendments to the template (I.e. you have several shareholders with different requirement) simply select ‘Do not send’, submit the ticket and then choose an email template after and amend as required. 

In the email that is then populated we ask the customer to provide the following information:

How to run a manual search on Cross Core

Log in via the link below:

https://ukid.uk.experian.com/EIH/

The log in screen will present as follows. Use your log in credential to log in to the site.

Use the drop down under Process Configuration and select ‘authenticate’

On the next screen complete the following 2 sections

And press ‘run query’ 

The result will look as follows:

For a result to pass the authentication index needs to be 40 and above. 

PEP/ Sanctions list Process

In financial regulation, a Politically Exposed Person is someone who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.

If you come across a customer on Cross Core that is potentially a PEP, first download the document and review the result to see if it is a false positive. If for example your customer’s name is Kasher Khan (no middle name as per DL) and the Cross Core PEP result points towards a K IMRAN KHAN OR K AHMED KHAN then you do not have to send a PEP letter and mark in the notes section that the result was based on a false positive. 

For the following 2 results there is no need to send a PEP letter:

“Non exact PEP or Sanction match” - Where we receive a U133 or U134 and the FIRST and LAST names are not an exact match, 

“PEP or Sanction Match where source is 'Website" - Where there is a match, but the source is 'Website" 

If we risk assess that the customer is potentially a PEP then we need to email the PEPs declaration letter which will need to be signed and returned by the customer.  We request the customer to provide us with certified Identification and proof of address to us.  Send Email Template - AML - PEP Letter

1. If our customer signs the letter and agrees they are not a PEP and includes all certified docs – Confirm with Team Leader before you process with the application.
   
2. If our customer confirms they are a PEP - This needs to be passed to your Head of Customer Services along with all certified documents for consideration.
   

NOTE: Make sure that you (Desk) delete the PEP attachment from the email and complete the letter adding the customer’s name and company name at the top before sending out the email, (CRM) prepare your PEP letter (complete name and company name) and attach to the email.

NOTE: We can accept both signed and scanned signatures (wet) as well as electronic signatures. However, we cannot accept a typed signature

Download the document and review the PEP/Sanction section at the bottom of the page

In the above example the identity has been confirmed at the required level, meaning the person does live at the address provided, however, due to a possibility of him being on the Sanctions list or being a PEP (Politically Exposed Person), the AML refers.

To complete your due diligence for this being on the Sanction list, see if you can find the list – US-Federal Housing Finance Agency to verify if the person is listed here/ if a direct match with our customer and escalate to Compliance if in doubt. 

Anther possible result you may across with in the Sanction’s results is the following: UK-Disqualified Directors. If this happens you need to verify the information via the link below:

 https://www.gov.uk/search-the-register-of-disqualified-company-directors

Write an email to the customer using the following wording:

As part of our due diligence requirements for formation of companies, the ID check results for the person above has indicated there may be a Company Director disqualification against a person with the name ***enter name*****.

A ban from being a director of a company at Companies House is normally issued by the Courts and the Insolvency Service. A ban remains in place for 15 years and its a criminal offence to hold such office under a ban.
Further if someone has been made bankrupt, they are also prevented from holding the office of director whilst still an undischarged bankrupt.

Have you ever held the office of a Director before?

If so, please provide the details of the Company

Was that company dissolved?

Were you ever subject to a disqualification to be a director?

If so, please further details?

Have you been made bankrupt?

If so, are you currently an undischarged bankrupt?

If so, please provide details.

Once we have received the above information, we will be able to review the due diligence and advise the next steps

There are instances where we are not able to provide RA service to customers from a certain country that is on a Sanctions list. If in doubt, verify via the link below:

https://bscn.nl/en/sanctions-risk-list-countries

There are applications that we automatically block on TFC, where the customer is either based in a country on the Sanctions list, for example China, or the billing address for the card used to purchase the package is from one of those countries. The customer can make the purchase and fill in the application form, however it does not get sent to Companies House or the AML queue. Instead, the application is rejected, and you can verify this by checking the info section on TFC.

The above decision to block a customer from a given country is based on a decision that we are taking as a business and a full list of countries that we cannot provide our services to can be found via the link below:

Higher Risk of Money Laundering v 2.2 updated

Again, if in doubt on how to proceed, please pass on to management or compliance for review. 

If your customer resides at the given country, then advise that we will not be able to go ahead with the application and offer a full refund. Check with management or compliance if in doubt.

In the other scenario, you identify that the customer might be from a country on a world wide sanctions list which we do not block automatically. Verify the information via the link below:

https://sanctionssearch.ofac.treas.gov/

Should the result uphold, pass this back to Compliance for review. 

Corporate Shareholder request

A Corporate shareholder request refers to an application where the customer has put a company as a shareholder rather than (or in addition to) a person.  You will be able to spot this in the queues as there is no information listed in the shareholder section (However, where the company also has a person shareholder listed on the application, the queue will look as normal and the only way to spot a corporate shareholder is via the admin hub/info section). This will look as follows:

To review all information on the company you will have to navigate to the Info section in the TFC admin hub.

Here you will be able to view the director they have added (this will need to be a person – minimum requirement) and the details of the corporate shareholder.

As part of our AML requirements, you will now need to request AML documents for the (person) director and for the majority shareholders (25% share and more) of the corporate shareholder. Review the provided information for accuracy by bringing up the company details on Companies House. Use template AML - UK Further Docs - Corporate Shareholder. 

Document review/ What documents can we accept

As we can now view the ID document that was uploaded during the filing flow (via Cross Core only) we can verify if that meets our requirements and request a different type of ID only if necessary. As part of the application customers are only permitted to upload a UK or International passport or a full UK Driving License.  Unless the customer has uploaded a different kind of ID or Provisional Driving License, we do not have to request another type of ID. Please see the link below for accepted type of IDs:

https://www.gov.uk/government/publications/proof-of-identity-checklist/proof-of-identity-checklist

If for example the customer has uploaded an ID document that we are unable to accept, you can request for example a birth certificate or Firearm or shotgun certificate instead. Run this past Compliance if in doubt or if you are unsure if the document provided is acceptable. 

In the case of an AML result that returns as refer or failed we can request a proof of address (POA) document to verify that the customer lives at the address entered on the application. 

 The POA can be one of the following:

1 x Proof of Residential Address (must be dated within the last 3 months)

1. Utility Bill (Gas, Electric or Water)
   
2. Bank/ Credit Card Statement
   
3. Council Tax bill
   
4. Telephone Bill (landline only)
   

NOTE: We can use a full driving license as a POA if this is not used for the name evidence (proof of ID) at the same time. An additional proof of ID document must be present in this case. 

For our UK customers the following criteria must be met for the POA document:

1. All sections must be clearly visible in general 
   
2. Dated within the last 3 months
   
3. Must show the full page (e.g. some customers like to fold the page so only the address part is visible on the bank statement. We do need to see the full page, including the financials)
   
4. The name and address must match the name entered on the application
   
5. Screenshots are permitted provided the whole statement/bill is showing
   
6. Document must be attached to the email – no OneDrive access etc
   

Please see examples below of what we cannot accept:

The above statement is only a section of the full page and has redactions on it. Go back to customer to request a full copy of the statement and assure the customer that all data is kept confidential and that we do not review or take the actual financials into consideration. However, a document that is not shown in full and has alterations made to it, no longer represent an original document, hence cannot be accepted. 

Should the customer return the requested documents and they match what is entered on the application you will then go back to the customer requesting further information by using the script below:

Based on the documents you have provided we are not able to satisfy our due diligence requirements at this stage for MR XXXX.

To assist with our due diligence, we need you to confirm the start date of Mr XXX residing at the address provided. If it is less than three years, we will also require your previous address and a copy document to evidence the same.

Additional proof of address you can consider if the official list of accepted documents has been exhausted/ customer is unable to provide additional documents (e.g. no bills in their name):

1. Tenancy agreement or completion statement/title deeds
   
2. Visa/ Travel documents
   
3. Approval letter to use the address/ run AML on person they are staying with – However, this involves extra cost so will need to be approved by a manager prior (if possible, run manual search on Cross Core)
   
4. In the absence of any available accepted POA request any other official document received in their name (e.g. NHS letter, DVLA letter etc). Again, if in doubt, run this past Compliance presenting the case with all available documents attached and request a review
   

Please review the link below for further details, tab ID Exception Process

AML = High Risk Alerts

Non UK AML requirements

Certification process

Certifying documents

If Certified documents are being obtained outside the UK the documents must be certified by an individual, we can independently verify.

We would accept one of the following:

Individuals within the EU can find an individual from either the notary list (select the relevant country) or from the list of lawyers on the Government list

1.   https://www.gov.uk/government/collections/list-of-lawyers
   

1.    https://notaries-directory.eu/
   

Use one of the templates below depending on where the customer is based and if the request was found in the UK or non UK queue or in the on behalf of queue, hence requiring for us to check the representative as well. You may need to tweak the template a little bit based on the situation, e.g. representative is in the UK but his/her customers are non UK, hence the representative is not required to have his/her documents certified. Use template: AML - Non UK Docs/Int. ID Check

Same as our UK residents we will ask for the following documents to be certified (and translated if applicable):

1 x Proof of ID

Current & Valid Passport

Current & Valid UK Full Driving License

 

1 x Proof of Residential Address

Utility Bill (Gas, Electric, Water)

Bank or Credit Card Statement

Council Tax Bill

Landline Telephone Bill

TV License

Again, based on the circumstances we may be able to accept documents from non UK customers that have not been certified by a public notary, e.g. have been certified by a solicitor instead, provided this is someone we can verify independently. Escalate to management or speak to Compliance if in doubt.

International Individual Check (Smart Search)

For those non UK customers who are not able to get their documents certified or simply prefer an online service we can offer our International ID check via Smart Search. 

Note: It is currently not possible for the customer to select this option during the filing flow or for the AML agent to add this feature (and charge them) whilst in the AML queue. The process to follow now is to send an email to the customer using the following template: AML – International ID check. This will give us permission to perform this check and for us to take payment from the customer after incorporation of the company. Should the formation not go ahead for whatever reason (failed AML check or other), we will do a refund minus the fee for the international check. The charge for this AML check is currently £12 including VAT.

We only perform the basic with facial recognition check and for that we need to verify if the document from the issuing country allows for this check to be performed on Smart Search. ID documents with an MRZ (Machine Readable Zone) typically allow for this feature. 

The following types of documents can be used for the basic with facial recognition check:

4. Passport
   
5. Driving License
   
6. ID Card
   
7. Residence permit 
   

Once the customer has agreed to the conditions you can check on the AML International ID document via the link below if the ID document can be used in the process: 

AML International ID

Tab: AML International ID checks

If the ID document can be used in the process you can go to Smart Search and select the option below:

Complete the following section, entering the gender, title, full name and DOB as well as current address

On the next page you will need to select the Issuing country, type of document and the Scan type – always Basic with Facial Recognition

In the example above, we have selected a passport from Australia. In the next step you will need to select the upload method – Send an upload link to your client and enter the client’s mobile number. The customer will now receive a link which will allow him/her to take a picture of his/her ID document and take a Selfie. Based on these two pictures, Smart Search will establish the likelihood of this being an authentic ID document and the person performing the check being the person in the document. 

Now enter the customer’s details on the AML International ID document, tab – AML International Payment

Once the client has completed the process, we will receive a message from Smart Smart to the TFC inbox labelled Smart Search International Individual Check Update. The body of the email will look as follows:

You can now look up the customer/account via the SSID number or the customer’s name via the AML International ID document (tab – AML International Payment) and approve the application. Once the company has been incorporated you will need to masquerade into the customer’s account and add the service and take the payment.

Should you not be able to take the payment (e.g. insufficient funds) then call the customer and mark your call attempts on the spreadsheet.

If the AML check fails due to insufficient picture quality for example and we need to resend the link and attempt the process again, we are being charged by Smart Search for an new ID check so we will need to charge this to the customer as well. 

A failed international ID Check will look as follows:

Review the document image and Selfie at the bottom of this page. Most likely the Selfie or the documents (or both) are not clear enough to make a full identification/comparison. Advise the customer that the check will need to be redone and that he/she will be charged again for this service. 

Check & Send service

We are now also running AML checks on customers that have purchased the C&S service but since this task is covered by the AML team the process is described below:

Customers are offered this service during the filing flow at a charge of £7.50 plus VAT for us to review the application and spot any errors/make recommendations before the application is submitted to Companies House. These are the sections that you will review and email the customer with suggestions regarding this:

Company name

Name availability (at the time of checking), does your chosen name contain a sensitive word that will need permission of use from the relevant body or is there an obvious spelling error that we have noticed.

Refer the customer to Companies House Sensitive word/ expression list for contact details of the relevant bodies should they need to request permission to use the word:

https://www.gov.uk/government/publications/incorporation-and-names/annex-a-sensitive-words-and-expressions-or-words-that-could-imply-a-connection-with-government

Registered office Address

Is the customer using RA or have they selected a residential address as their registered office address? If the latter applies, asked them to contact us for further information on RA

Standard Industrial Classification (SIC)

List the code currently selected and ask them to confirm if they are happy with this or if they wish for us to recommend a more suitable match 

http://resources.companieshouse.gov.uk/sic/

Shareholder details

Check the application to make sure the customer has entered the name and DOB correctly and in full and verify that the residential address is accurate. You can verify if a DL was uploaded or if the address is evidently a business address and not a residential address

Occupation

Make the customer aware that the address will be shown on the public register and is in relationship to the position they hold within the company they are forming. We no longer recommend for this to be changed to director

Use the template: CnS results template and remember to remove any section that does not apply!

Review those applications that have been in the queue for a few days and call the customer to make sure they have received the email and to make sure the formation process is not delayed for any reason. 

Appendix 

SMART SEARCH PEP PROCESS (process no longer in use)

If you come across a customer on Cross Core that is potentially a PEP you will first need to run the AML search from the Smart Search queue to load the details in the Smart Search database. Open this in a new browser and open the relevant queue again.

Once you have clicked ‘search again’ on from the queue, you can log into Smart Search and do your due diligence from here.

https://www.smartsearchsecure.com/dashboard

Scroll to the bottom of the page and enter the customer’s name in the ‘Retrieve Previous Search’ box

This will then bring that person’s search result and you can navigate to the top left corner to perform your due diligence.

Click on the red person which will then present you with the following screen:

The only way to really exclude someone as the PEP in question is if you have a DOB or a picture that you can compare it to. In our example there are 5 potential PEPs under the name of David Wilson. Four of them have a DOB attached to it that does not match our client’s DOB so you can proceed by clicking ‘no’ in the Your Client? section. The entry with no DOB has a picture that you could compare it to and rule out that this is our customer, if no picture is present and only a Citizenship or Residency is listed there is not enough information to make a decision.

In case that our customer is not a PEP and you can exclude him via the due diligence section on Smart Search, put a note in the note section in the AML queue to state why this customer is not considered a PEP before approving the application. 

If we risk assess that the customer is potentially a PEP then we need to email the PEPs declaration letter which will need to be signed and returned by the customer.  We request the customer to provide us with certified Identification and proof of address to us.  Send Email Template - AML - PEP Letter

1. If our customer signs the letter and agrees they are not a PEP and includes all certified docs – Confirm with Team Leader before you process with the application.
   
2. If our customer confirms they are a PEP - This needs to be passed to your Head of Customer Services along with all certified documents for consideration
   

Understanding the MRZ section on passports and DLs

What the passport number tells us:

1. The first 9 characters of the second line of the passport’s machine-readable zone is the document number. The 10th character is there to verify the correctness of the number and is calculated using a special algorithm based on the first 9
   
2. The next 3 characters indicate the citizenship of the passport holder – GBR = Great Britain
   
3. The next 6 digits is the date of birth in the YYMMDD format, and the character following that date is the check digit, which is calculated by a special algorithm based on the date of birth. The next character indicates the gender of the passport holder: male (M), female (F)
   
4. The next 6 digits indicate the validity period of the passport in the YYMMDD format, followed by the check digit
   
5. The next 14 digits are optional data (at the discretion of the issuer to help identify the person). If not available these 14 digits are will filled with placeholders <<
   
6. The second last number is a personal number but again if not applicable it will be entered as 0
   
7. The final digit is a check digit calculated using all the characters in the bottom line, except for the characters indicating the gender and citizenship.
   

1. Contains the first five letters of the surname. If surname is less than five characters in length, the remaining spaces will comprise of the digit 9.
   
2. First and last numbers are the year of birth. Second and third numbers are month of birth. (Note: in the case of female driving license holders, ‘5’ is added to the second digit, this means that the second digit will be 5 or 6). The fourth and fifth digits are the day of the month of birth.
   
3. The first two initials of your forenames. If you have only one initial, then the second character will be a ‘9’.
   
4. Computer check digits.
   

How to check the authenticity of a passport

If you have concerns around the authenticity of passports in general, you can go to the link below and that will show you what a passport from a given country should look like:

http://www.edisontd.net/

Steps on cancelling RA from an application after submission (to the AML queue): 

1. Reject from the AML queue
   
2. Go to admin hub, click on ‘edit’ and remove RA service
   
3. Masquerade into the account
   
4. IF eformation or Essential package (RA service was manually selected by the customer), go to the overview page and click on the RA service and it will let you remove RA and add a new address - resubmit
   
5. IF Entrepreneur or Super package (RA embedded in the package) you will need to paste one of the following URLs into your browser after you masqueraded into the account:
   

TFC:

https://www.theformationscompany.com/flower/filing/cs-business-address

LZ:

www.theformationscompany.com/flower/lzukFiling/cs-business-address

 

1. Remove RA and add a new address ( make sure that you have confirmed the address prior with the customer) and resubmit.