Client Identification

The Money Laundering Regulations stipulate that in the majority of cases, a relevant (i.e. registered) person “must verify the identity of a customer before the establishment of a business relationship or carrying out an occasional transaction.”

The regulations don’t stipulate the specific information and documents that need to be obtained although comprehensive guidance is provided by the Joint Money Laundering Steering Group.

In addition, in accordance with the Money Laundering Regulations, the latest JMLSG guidance does not stipulate that identification is required for every transaction carried out. There are situations where, due to the low risk of money laundering taking place with a particular product or service, customer due diligence can be relaxed. Guidance from JMSLG is extensive both generically and in terms of the sector in which a registered organisation is working.

Where verification of identity is considered essential, the following is generally deemed acceptable in terms of the information that should be gathered:

At the outset, the following information should be obtained:

• The customer’s true name.
• Their correct permanent address, including postcode.
• Occupation
• Date of birth.
• Nationality

This information should then be verified by checking identity. Some examples of acceptable proof of identity could be any one of the following original documents:

• Current signed passport.
• Current UK photo-card driving licence.
• Current full UK driving licence.
• HM Revenue and Customs tax notification.
• Armed Forces identity card.
• National identity card (non-UK residents).

A full list of documents that may be acceptable is provided under the JMLSG Guidance.

Each firm will have its own policy so it is important for you to know your organisations policy and procedures