In the case of direct personal clients (ie where no
introduction has been made), a regulated person should aim to interview
a prospective client in person.
Although a personal introduction from, for example, a
known and respected client or an employee may be useful, it is unlikely
that it will remove the need to verify the identity of a prospective
client in the manner provided in these Guidance Notes. Any introduction
should, in any event, be in writing and should contain the full name and
address of the prospective client together with as much personal
information as is relevant.
(b) What information should be obtained?
Regulated persons should obtain the following
information concerning all prospective direct personal clients:
(i) full name and names used together with the
reason for any aliases;
(ii) date and place of birth;
(iv) current permanent residential address;
(v) telephone and fax number;
(vi) occupation and name of employer or, if
self-employed, the nature of the business;
(vii) the reason for establishing the account and
the nature of the business to be conducted;
(viii) estimated level of turnover expected for the
(ix) the source of funds (i.e. generated from what
transaction or business.)
(c) What evidence of identity is acceptable?
Identification documents, either originals or legally
certified copies, should be pre-signed and bear a photograph of the
applicant for identification at the interview. The following are
(i) a current valid full passport; or
(ii) a full driving licence (provided it bears a
photograph of the applicant).
Note that if, in exceptional cases, it is decided that
a personal interview is not necessary, it is neither safe nor reasonable
to expect a client to send an original passport or driving licence by
post or courier service. In those circumstances, a legally certified
copy should be requested.
(d) Documents that are not acceptable.
Identification documents that do not bear both a
photograph and a signature or that are easy to obtain are not
appropriate as sole evidence of identity. Examples include:
(i) birth certificates;
(ii) credit cards;
(iii) provisional driving licence;
(iv) business cards;
(v) social insurance, social security or health service cards; and
Any photocopies of documents showing photographs and
signatures should be plainly legible.
(e) Further verification
Regulated persons should also take appropriate steps
to verify the name and address of prospective clients by at least one
further method, for example:
(i) obtaining verification of identity from a
respected professional who knows the applicant (a suitable form for
this purpose is set out in Appendix C.2);
(ii) checking the register of electors;
(iii) making a credit reference agency search;
(iv) checking a local telephone directory;
(v) requesting sight of a recent property tax or
utility bill (care must be taken that the document is an original and
not a copy); or
(vi) using one of the commercial address