Overview Of Identity Documents Needed

When taking on a new client what identity documents (“ID”) are needed?

The answer is that one document needs to show the individual’s name and another document is needed to show their address.

The documents that are required are official documents such as driving licence, passport and recent utility bill.

Why Is This Required?

This documentation is now required in light of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

An Insolvency Practitioner has to ensure strict compliance with money laundering legislation and ensure that in each and every case a risk assessment is undertaken concerning a client in terms of being a party to or being associated with money laundering.

The requirements of Regulation 28 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 confirm that we are obliged to verify the beneficial owners of an entity or person that becomes a client of the firm. We must identify and verify the entity/legal person and Board and identify the beneficial owners and take reasonable steps to verify them.

Oliver Elliot Approach

When seeking to verify your identity we will ask you for a scanned copy of your driving licence and passport in most cases. We may in some instances request further documents such as a recent utility bill within the last 3 months.

Save for instances of impracticality in most cases we will require such ID for each Director/Designated Member in the case of a Company/Limited Liability Partnership (“LLP”) and any Shareholder or Member that has 25% or more of the beneficial interest in the Company/LLP. In the case of an unincorporated Partnership, the ID we require is for all Partners who have a 25% or greater share of the Partnership.

In instances of impracticality then we may make arrangements to obtain sight of ID for example online through a Virtual Meeting conference facility and or seek to place reliance upon your accountants and or solicitors who might be happy for us to rely upon their customer due diligence (KYC) procedures. However, this will be very much the exception rather than the rule. In the vast majority of cases, the provision of ID will be considered mandatory.

As part of our terms of engagement, we will seek to verify your identity without you having usually to undertake certification procedures. With your written consent we will process your documents electronically using the personal data within the same to check your identity using Veriphy.

Veriphy will provide us with a pass or fail clearance. If Veriphy is unable to validate your identity for any reason then we will do further checks and require certified copies of your official documents.

If you have any queries concerning the processing of your personal data then please email at privacy@oliverelliot.co.uk and the firm’s privacy officer (Elliot Green) will look to address any concerns that you may have.

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Disclaimer

This page What Identity Documents Do We Need? is not legal advice and should not be relied upon as such. This article What Identity Documents Do We Need? is provided for information purposes only. You can contact us on the specific facts of your case to obtain relevant advice via a Free Initial Consultation.

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