In common with other professional services firms, we are required to identify and verify the identity of our clients, including any beneficial ownership, for the purposes of the UK anti-money laundering regulations (AMLRs). We will request various information and documentation from you in order to meet our obligations under the AMLRs. This is referred to as Customer Due Diligence (CDD).
Information you provide will be retained in accordance with our data retention policy.
The purpose of CDD is to confirm your identity as a client. We will do so through a number of means including searching of electronic databases, requesting formal documents from both you and from independent sources.
For some clients, information we have gathered or provided by you may require us to ask further questions or require further evidence from you. We try and keep our requests to a minimum but we do need to meet our legal obligations.
Please note that we are unable to provide the services you require from us until we have satisfactorily completed our client identification and verification procedures.
We will request a form of photo ID, usually a current passport, picture driving licence or photo national Identity card. In some cases we may request proof of address (usually a utility bill less than 3 months old).
We prefer to see the original documents, but where this is not possible, we will accept certified copies. These copies must be certified as a true copy and the picture a true likeness. We will send you an ID certification form for your use should this be the case.
For individuals resident in the UK we can use electronic data checking to assist us with ID verification. Such checks leave a light footprint, different to that left by a credit check. We will advise you if we propose undertaking such a check. If the check is able to return a verified result formal copies of documents, as mentioned above, may not be needed.
For incorporated entities, in addition to confirming details regarding the entity itself we need to understand and verify any beneficial owners (own or control more than 25% of the voting rights or are entitled to more than 25% of the profits) or, if none those individuals that run and control the entity.
If the entity is part of a group will request a copy of the group structure initially and then, depending on the structure, will request information as we require.
We will try to verify the identity of incorporated entities by reference to the relevant company regulator’s register first. For companies not incorporated in the UK, while we may be able to obtain some information directly ourselves, it’s likely that will be contacting you to provide verification documentation. Such documents may include certificates of incorporation, memorandum & articles of association (or other constitution documents), and directors and shareholder/member registers. If these are not produce in English we will require the copies to be translated and certified accordingly.
We acknowledge that not all individuals will be able to provide our preferred documents, or that you may be charity, trust or other entity type. Your contact at Price Bailey will be able to advise you of alternative documents we can accept to meet our legal CDD requirements or you can contact the Price Bailey Compliance team at [email protected].
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