Customer Identification & Recent Changes

Customer Identification

Customer identification is needed for all new customers before dealing with them. It must be kept for five years and must be re-obtained if the customer changes name or address.
Identification must also be re-obtained if there has been no customer contact for 12 months or more.

Recent Changes

There are several changes which will affect businesses supervised by HM Revenue & Customs (HMRC). The main ones are:

The fit and proper test

Part of the registration process for Money Service Businesses and Trust and Company Service Providers: it applies to particular individuals within these businesses. The decision as to whether an individual is fit and proper will now be based on the risk of money laundering or terrorist financing.


A registration may now be cancelled where, after registration, the ‘relevant person’ is no longer able to meet the conditions for registration or where the relevant person has failed to provide HMRC with information it has requested by notice.

Relevant person

A relevant person is a person or business to whom the regulations apply. The definition has been widened to include those persons who HMRC believes, or suspects to be, a relevant person.


A penalty can now be imposed for failure to provide information required by notice.


A legal gateway now exists between supervisory authorities which allows them to share information subject to certain conditions.