“We adhere to the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007, which require us to promptly obtain satisfactory evidence of your identity. We are also obligated to report certain activities to the authorities as outlined in these laws.
To comply with current International Anti-Money Laundering regulations and best practices for Know-Your-Client procedures, we must gather the following items and information for each Beneficial Owner, Director, and Shareholder of any Company we serve. It’s important to note that specific jurisdictions may have additional requirements, and both local and global rules undergo regular changes. Therefore, variations in the requested information may occur without prior notice.
While it is acceptable for another company to be listed as the Beneficial Owner of the new Company, we must still obtain details about the individuals who are the ultimate Beneficial Owners of that other company. This is because, ultimately, the Beneficial Owners of a Company are always individuals.
To streamline the process and minimize any delays or inconveniences in gathering the necessary information, we have established the following minimum requirements. However, please be aware that we reserve the right to request additional information if we deem it necessary at any point.”
TYPE OF BENEFICIAL OWNER 1 | CLIENT DUE DILIGENCE (“CDD”)/INFORMATION REQUIRED 2 |
---|---|
INDIVIDUAL | Proof of Identity 1 Proof of residential address 2 Professional Reference Letter 3 |
PRIVATE COMPANY | Certificate of Incorporation Memorandum and Articles of Association (or equivalent) Register of Directors Register of Shareholders CDD on any shareholders |
PUBLIC (LISTED) COMPANY | Listing certificate CDD on at least two directors as per ‘individual’ Board resolution establishing offshore entity 4 |
TRUST / FOUNDATION TRUST / FOUNDATION | Deed and ancillary documents CDD on Trustees as per ‘Type’ CDD on Settlor as Individual List of beneficiaries if not disclosed in Trust Documents (CDD may be requested on some or all beneficiaries) |
PARTNERSHIP / PARTNERSHIP AGREEMENT | CDD on Partners Partners’ resolution establishing offshore entity 4 |
OTHER ENTITY | Please contact us for guidance |
- When providing copies of documents, it is important that they are certified as true copies. Please refer to the Guidelines for Certification provided below. If you have alternative documents that are not specifically listed, please obtain our prior approval before submitting them.
The following forms of proof of identity are acceptable:
- Valid Passport
- Driving license (if it contains a photograph of the individual)
- National ID Card
- Armed Forces ID Card
For all Passports/Identity Documents, please ensure that the following criteria are met:
- The document is currently valid and displays the issue and expiry dates.
- The photograph is clear, and all features are easily identifiable.
- The page showing the individual’s signature is included.
- The place of issue and passport number details are included and can be clearly read.
- The document includes information about the individual’s nationality.
Guidelines for Certification: When certifying documents as true copies, please follow these guidelines:
- The certification must be made by a professional person or authority, such as a lawyer, notary public, or bank official. They should clearly state their name, position, and contact details.
- The certification should be dated and include an official stamp or seal.
- The certifier must confirm that they have seen the original document and that the copy is a true and accurate representation of the original.
- The certifier’s signature should be present, indicating their agreement with the certification.
- If the document consists of multiple pages, each page should be certified separately.
By adhering to these guidelines, we can ensure that the copies of the documents provided are verified and meet the necessary requirements for identification purposes.
2. We require acceptable forms of proof of residential address. The following documents are considered valid:
- Valid, full driving license (unless it has already been provided as proof of identity)
- Utility Bill (such as Gas, Water, Electricity, etc. Please note that we cannot accept a mobile telephone bill)
- Television License
- Home/Motor Insurance Policy Document or Certificate
- Bank/Building Society/Credit Card Statement from a recognized Financial Institution (please note that our discretion is final)
- Council Tax or Rates Bill
If you are submitting third-party documentation, it must be from a recognized and verifiable provider. Additionally, the document should not be more than three months old at the time of submission.
We understand the importance of verifying your current residential address, and these documents serve as reliable evidence for that purpose. Please ensure that the documents you provide meet these requirements.
- Professional references:
As part of our compliance obligations, we are required to obtain a reference from a professional individual, such as a lawyer, accountant, or bank manager. This reference may be contacted for verification at a later stage. The reference should include the following details and must be presented on the professional’s official letter-headed paper:
“I/we confirm that I/we have known Mr/Mrs/Miss/Ms [Insert Full Name] for [Insert Number of Years] and can verify that he/she is a genuine and suitable individual to operate a company registered in [Insert Desired Jurisdiction]. Furthermore, I/we confirm their suitability to manage any associated bank accounts. We affirm their credibility and confirm their usual residential address as follows: [Insert Residential Address].”
- An extract of Board/Partner meeting minutes can be accepted as evidence if it is certified as a true extract by a director or the Company Secretary.
To ensure the authenticity and reliability of the professional reference, it is essential that it includes the specified wording and is printed on the professional’s official letter-headed paper. This reference serves to verify the character and suitability of the individual in question for operating a company in the chosen jurisdiction, as well as managing any relevant bank accounts. Additionally, a certified extract of Board/Partner meeting minutes can be provided to support the application process.
Please ensure that the professional reference and any extract of meeting minutes meet the aforementioned requirements for accurate and valid verification.
GUIDELINES FOR CERTIFICATION REQUIREMENTS
Who can certify your documentation?
Your documentation can be certified by any of the following individuals or authorities:
- An independent lawyer or accountant
- A bank manager
- Commissioner of Oaths
- Notary Public
- Justice of the Peace or member of the judiciary
- A British Embassy official
What should the certification wording include?
The certification should include the following wording:
- “A certified true copy of the original document”
- The certifier must use an official stamp that clearly states their company name and address
- They should sign and clearly print their name
- The certification must be dated
- The certifier should indicate their position or official capacity on the copied document
- If applicable, the name of the regulating body of the certifier should be included (such as ACCA, Law Society, FSA, etc.)
- If applicable, the certification should include the registration number issued by the regulating body
By adhering to these guidelines, the certified copies of your documents will be deemed valid and reliable for our purposes. The certifier’s professional standing and their official endorsement ensure the authenticity and accuracy of the copies. Please make sure that the certification process includes all the mentioned elements.