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client money


A Client Money account is one that’s held in your name but holds funds that are beneficially owned by your clients or third parties. As part of our reporting obligation, we must tell HMRC if accounts are owned by people from the US or other foreign tax residents.

In carrying this out, we have recently contacted you to ask you to tell us if an account you have with us is operated as:

  • a general client account
  • a designated client account
  • an escrow account
  • not a Client Money account

What we need to know about your clients 

Thank you for helping us meet our obligations to HMRC. To give us the information we need about your Client Money accounts, please follow the instructions that apply to you.

Are you a financial institution?  

If YES, please complete this tax details form and return it to us.

If NO, please refer to the account summary form we sent you and continue with the actions below. 


If you know of any CM accounts not listed, please add the account number(s) to the blank ‘Client Money – summary form’ page and complete details for these accounts.

What your clients need to do  

Where you have indicated that an account is operated as a designated client account (non-escrow) on the summary form we sent you, please ask each of those clients to complete and return the relevant tax details form electronically. There are two types of form: individual (including sole traders) and entity.

Individuals (known legally as natural persons) should fill in the first form. This includes sole traders. The second form should be sent to clients that are entities, for example a limited company or a trust.

  • Individuals should complete the Individuals form below.
  • Entities should complete the Entities form below.

Each client needs to email their completed form to you before you send them to us. Once you’ve had all forms back from your clients, return them to along with the account summary form, within 90 days of when we contacted you.

For details about how we use the personal and financial information of our clients, please see our full privacy notice at

Frequently Asked Questions

  • Why are CM accounts important to HMRC?

    Under FATCA / CRS we are obliged to report beneficial owners to HMRC where they have a foreign country of tax residence. Some of your clients may fall into this category and may therefore need to be reported to HMRC.

  • Who should I contact if I have any questions in relation to this issue?

    Your Banker and their support staff will be best placed to answer your questions or address your concerns.

  • Do I need to respond for accounts that have been closed?

    Yes, you have to respond for all accounts which have been listed on the letter you have received.

  • What are FATCA and CRS?

    FATCA (Financial Account Tax Compliance Act) and CRS (Common Reporting Standards) are tax transparency reporting legislation that are written into UK law with obligations on all UK Financial Institutions to report annually to HMRC.

  • What is a Designated Client Account?

    This is any account held by us in your name and which is designated as holding funds beneficially owned by one or more clients who are named or otherwise identified in the title of that account.

  • What is an Escrow Account?

    This is an account held by a third party on behalf of the beneficial owner of the money in the account. Escrow is a legal concept describing a financial instrument whereby an asset or escrow money is held by a third party on behalf of two other parties that are in the process of completing a transaction. Escrow accounts might include escrow fees managed by agents who hold the funds or assets until receiving appropriate instructions or until the fulfilment of predetermined contractual obligations. Money, securities, funds, and other assets can all be held in escrow.

  • What is a General Client Account

    This is an account held by us in your name and which is designated as holding funds beneficially owned by one or more clients who are not named or otherwise identified in the title of that account.

  • What is an entity?

    An organization that conducts business, engages in a trade or similar activities. Types of business entities include but are not limited to — partnership, LLC, corporation, etc.

  • What is a natural person?

    Not an entity - a human or physical person rather than a legal person which may be a private or public organisation.