ANTI
MONEY LAUNDERING PROTECTION
UK
law requires that all insolvency practitioners
among other financial services professionals guard
against possible money laundering (the process
by which the proceeds of crime become 'clean').
The principal requirements are as follows.
Proof of Identity and Address - Personal
Clients and Directors / Controlling Shareholders
We are required to obtain evidence of both your
identity and your home address before we can do
work for you or accept money on your behalf, other
than in very limited circumstances. You will need
to bring into the office one original document
proving your name and one proving your address,
so that we can take copies. Acceptable documents
are listed as follows:
List A
– identity.
-
Current signed passport
-
EEA member state
identity card (please note that UK National Identity
cards are no longer valid as proof of
identity for anti-money laundering purposes)
-
Residence permit
issued by the Home Office to EEA Nationals on sight
of their own country’s passport
-
Current EEA or UK
photo-card driving licence or a blue disabled
driver’s pass
-
Current full UK
driving licence (old version) – old style
provisional licences will not be accepted
-
Original notification
letter from the Department for Work and Pensions
(DWP) confirming rights to benefits*
-
Self-Employed in the
Construction Industry – current photographic
registration cards for individuals and partnerships
CIS4, CIS4(P), CIS4(T) and CIS6
-
HM Revenue & Customs
tax notification * – not a fP45 or P60 form
-
Current shotgun or
firearms certificate
List B –home address
-
Current electricity,
gas, landline telephone, or water/sewerage bill*
-
Local Authority
Council tax bill (current year)
-
Current UK driving
licence (old full licence or new photo-card licence)
if not used for evidence of name (old style
provisional licences will not be accepted)
-
Current EEA Member
State identity card (if not used for evidence of
name (please note that UK National Identity cards
are no longer valid as proof of address for
anti-money laundering purposes)
-
Bank, Building
Society, Credit Card or Credit Union statements or
Building Society passbook containing your address*
-
Most recent mortgage
statement from a recognised lender
-
Current local council
rent card or tenancy agreement
-
Original notification
letter from the Department for Work and Pensions
(DWP) confirming rights to benefits (if not used for
evidence of name)*
-
HM Revenue & Customs
communications addressed to the applicant at the
applicant’s stated address (provided HM Revenue &
Customs tax notifications have not been used for
evidence of name). Not a P45 or P60 form*
-
Current house or motor insurance certificate
*The document must be dated
within the last 3 months.
Exceptionally you can send us copies of documents.
You should not send original documents. The copies
need to have been checked by one or other of the
following: (a UK lawyer, banker, financial advisor,
accountant, Tax Consultant, teacher, doctor, minister of religion
or post master/sub-post master or your employer).
After checking the copy against the original document,
they must write on the copies 'I certify this to
be a true copy of the original document'.
Ideally, they should also stamp the documents
with their business stamp. They will also need
to write their name, address and telephone number
on the copy documents so that we can confirm the
details of their checking with them.
Extra Proof of Identity and Address Requirements
for Businesses
Unincorporated
businesses or partnerships
We will need identity and address evidence for
the individual partners or owners of the business,
unless we already have this as a result of any
personal instructions that you may have given
us. We will also need two documents confirming
the business trading address (normally a letterhead
and a blank sale invoice or blank delivery docket).
Private Limited Companies
We will need identity and address evidence for
the main directors and shareholders (unless we
already have this following private instructions).
As regards the company itself we rely on our own
searches at Companies House. However, we will
need confirmation of any changes in directors
and shareholders compared with those recorded
at Companies House. We will also need two documents
confirming the business trading address (normally
a letterhead and a blank sale invoice or blank
delivery docket).
Payment of our bills
We do not accept payment by cash.
Source of payment
We may need to know early on which bank or other
financial institution the funds you use to pay
our fees will be coming from. We may have to ask
you questions about how you acquired the funds
in the first place. We appreciate that some questions can seem intrusive but we are under
a legal obligation to obtain information from you.
Our Obligation To Report Suspicions of
Crime
If, during the course of our work, we become suspicious
or aware that money with which you are involved
comes from the proceeds of any crime (for example,
from robbery, benefit or other fraud, or tax evasion),
we shall be under a duty to make a report to appropriate
authorities without letting you know. This obligation
extends to any suspicion we have that anyone connected
with your case is involved with any criminal activity.
Conclusion
If you have any questions about these procedures,
please contact Peter O'Duffy of IP Services Ltd
or email poduffy@ipservices.co.uk. |