Company Identification

Companies can be popular vehicles for money laundering as complex arrangements can sometimes make it difficult to tell who owns them. As a result, care should be taken when verifying them.

Steps to take could include:

• Making sure that the person claiming to act on behalf of the company has the authority to do so.
• Identifying the individual people behind the business to find out who has control over the company and its assets.
• Checking that the company has a legitimate trading purpose and is not just a ‘brass plate’ company where its owners cannot be identified.

Corporate customers that are quoted on a recognised stock exchange are usually considered to be publicly owned and generally accountable. Consequently there is less need to verify the identity of individual shareholders. All that should be needed is:

• A copy of the certificate of incorporation or certificate of trade; AND evidence of the company’s registered address AND the list of shareholders and directors; OR
• A search of the file at the office of the Registrar of Companies or an enquiry via a business information service; OR
• An undertaking from a firm of lawyers or accountants confirming the documents have been submitted to the relevant registry.

Charities

A central register of charities is held by the Charity Commission

(www.gov.uk/government/organisations/charity-commission). Each charity has its own registered number. Checking the number and a correspondence address is a suitable method of verification.

The identity of the signatory should also be checked. Where there is more than one signatory, the identity of at least two signatories should be verified initially. When signatories change, checks should be made to ensure that at least one signatory has been verified.

Verify the purpose of the club or society and an address. Follow similar procedures as registered charities for checks on signatories.