Verification of Customer Identity Table - Identifying the types of acceptable verification material by customer type.

1.

TYPES OF CUSTOMER

 

Is the customer a company?

Go to 2

Is the customer an individual?                                       

Go to 3

Is the customer a trust?                                                            

Go to 4

Is the customer a regulated bank, investment firm or a life insurance company?

Go to 5

Is the customer a partnership?                                             

Go to 6

Is the customer a charity?

Go to 7

Is the customer an unincorporated association, society or club?

Go to 8

2.    

COMPANIES

Is the customer a publicly quoted company?     

Is the customer a private company?

Is the customer a subsidiary of a public or private company?     

2A. Publicly Quoted Companies

Company listed on LSE                 

               Evidence of Identity:

               (1) Copy of relevant page from the LSE’s list of companies (www.londonstockexchange.com) OR (2) photocopy of relevant page from FT confirming company is listed on LSE.

Foreign listed company                 

               (1) Copy of relevant page from the FSA’s list of recognised, designated or approved exchanges (www.fsa.gov.uk)

               AND

              (2) Evidence that the company is listed on the exchange (e.g. photocopy of relevant page from the relevant official list).

2B.  Private Company

Private company not listed on LSE or recognised exchange

               (1) Copies of (a) certificate of incorporation or equivalent AND (b) list of shareholders AND (c) list of directors and details of registered address AND (unless the company is a household name) (2) Evidence of identity and address of one director or shareholder of the company as for individuals at (3) below (who should be the person giving instructions).

2C.  Publicly Quoted or Private Company

Subsidiary of company listed on LSE

               (1) Evidence of parent identity as at 2A above

               AND

               (2) Evidence of parent/subsidiary relationship (e.g. copy of latest annual return).

Go to 2A

Go to 2B

Go to 2C

3.    

INDIVIDUALS

Evidence of identity:

(1) Evidence of name, including (i) certified copy of current passport OR (ii) EEA national identity card (note that no extra evidence of address will be required) OR (iii) UK or EEA photo driving licence.

AND

(2)  Evidence of address, including certified copy of (i) recent utility bill (not mobile phone) OR (ii) local council tax bill OR  (iii) UK or EEA photo driving licence (if not used for (1) above OR  (iv) recent bank or building society statement OR (v) recent mortgage statement OR (vi) Inland Revenue self-assessment statement or tax demand OR (vii) house or motor insurance certificate.

 

4.    

TRUSTS

Evidence of identity:

(1) Carry our identity checks for the trustee (if only one) or of two trustees (one of whom should be the person giving instructions) as for individuals at (3) above or the relevant entity type.

AND

(2) Evidence of appointment of those in (1) above as trustees.

 

5.    

BANKS, INVESTMENT FIRMS AND INSURANCE COMPANIES

Carrying on Business in the UK

Evidence of identity:

Copy of the relevant dated page from the on-line FSA register (www.fsa.gov.uk) showing that the entity is authorised by the FSA.

Carrying on Business in the EEA or FATF member country

Evidence that the entity is authorised to carry on business by the relevant local regulator.

Subsidiaries: (1) Evidence of parent’s authorisation to carry on business as above.

 AND (2) evidence of parent/subsidiary relationship (e.g. copy of latest annual return).

 

6.    

PARTNERSHIPS

Is the customer a professional partnership/LLP?

Is the customer an LLP (non-professional)?

Is the customer a non-professional partnership?

6A.  Professional Partnership/LLP

Evidence of identity:

(1) Evidence of existence of partnership from appropriate professional body (e.g. Law Society’s on-line register of solicitors) OR copy of relevant page from reputable directory.

AND

(2) Copy of page from reputable directory of the partnership’s trading address (note that this should not be the same directory as used in (1) above).

6B.  Non-professional LLP

(1) Copy of certificate of incorporation or equivalent

AND

(2) evidence of identity of two members (one of whom should be the person giving instructions) as for individuals at (3) above or the relevant entity type.

6C. Non-professional partnership

(1) Evidence of identity of two partners (one of whom should be the person giving instructions) as for individuals at (3) above or the relevant entity type

AND

(2) evidence of the partnership’s trading address (e.g. copy of relevant directory entry).

Go to 6A

Go to 6B

Go to 6C

7.    

CHARITIES

Charity in England or Wales regulated by the Charity Commission

Evidence of identity:

Copy of relevant dated page from the on-line register of charities (www.charity-commission.gov.uk) showing that the charity is registered with and regulated by the charity commission.

Other Charities

Follow requirements for the relevant entity type.

 

8.    

UNINCORPORATED ASSOCIATIONS, SOCIETIES AND CLUBS

Evidence of identity:

(1) Constitution or rules and names of all officers.

AND

(2) Evidence of identity of two officers (one of whom should be the person giving instructions) as for individuals at (3) above.

 

Jamie Curle is Special Counsel in Dorsey & Whitney's London Advocacy Group and specialises in civil fraud and asset recovery, banking and financial services litigation and cross-border disputes.

Contact Details:
Tel: + 44 (0)20 7826 4573
Email: curle.james@dorsey.com

 
 
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