In the UK, verification of a client’s identity must take place before the establishment of a business relationship or the carrying out of an occasional transaction.
As a general rule, where the firm has not acted for a client in over three years, the identity of the client should be verified as if they are a new client.
If the client changes during the course of a matter, the identity of the new client must also be established and verified as soon as possible.
Obtaining verification documentation
As part of the verification process, the organisation collates information about the client and the work the organisation will be doing for the client. We are required to retain copies of such documents. These documents may be subject to inspection by the regulatory authority.
The precise makeup of the documents, data and information we use to undertake due diligence measures will vary according to the nature of the client.
Obtaining verification documentation
Verification documentation may include:
passports
proof of home address
certificate of incorporation
electronic checks of suitable databases
evidence from reputable and reliable third party information service providers