Money Laundering & Identification Regulations
Last Updated: 01/09/2023
PLEASE NOTE AS OF 1ST SEPTEMBER 2023 WE HAVE UPDATED OUR MONEY LAUNDERING & IDENTIFICATION REGULATIONS FOR ALL NEW INSTRUCTIONS.
THE DOWNLOAD BUTTON WILL DOWNLOAD THE CURRENT TERMS EFFECTIVE FOR INSTRUCTIONS FROM 1ST SEPTEMBER 2023.
TO DOWNLOAD OR READ THE TERMS FOR INSTRUCTIONS FROM BEFORE 1ST SEPTEMBER SEE OPTION 5 BELOW
NEW - Money Laundering and Identification Regulations - EFFECTIVE FROM 1ST SEPTEMBER 2023
THESE TERMS ARE FOR ALL INSTRUCTIONS MADE ON OR AFTER 1ST SEPTEMBER 2023
FOR INSTRUCTIONS PRIOR TO THIS DATE PLEASE SEE SECTION 5
1.4 Help Sheet
1.1 Money Laundering Precautions
As part of our Anti-Money Laundering (AML) requirements, we must complete ID verifications on each individual involved in your matter. We class an individual as being involved in the matter if you wish them to be able to speak with us regarding the matter or anyone involved in a financial way, some examples are listed below:
– Anyone to be named or currently named on the deeds to a property-related transaction
- Family/friends gifting money towards house purchase
- Attorneys named on Power of Attorney
- Beneficiaries to an estate.
This list is not exhaustive so if you aren’t sure whether or not you need to list an individual, please contact and we will be able to assist in determining whether we will need to obtain information for the person(s).
If you are a business/organisation, we will need to prove that you have the authority to instruct us on behalf of the entity, we will need a signed letter or authority from any person with a 25% or more share in the organisation. In addition to this we will need each of these individuals to complete the ID verification.
One way we minimise the risk of money laundering is by knowing where funds are coming from - because of this our preferred method of receiving payment is via bank transfer or debit / credit card. In the same way if funds are owed to you as a client or a business on your behalf, we usually do this by way of bank transfer, speak to us if this will cause any issues. If we suspect that funds large or small being used for a transaction have come from proceeds of crime, we have an obligation to report this to the NCA (National Crime Agency) this may result in police and / or HMRC (HM Revenue & Customs) investigation; If you are concerned about how this may affect you, please speak with us.
1.1.1 Identity & Money Laundering Checks
The main way in which we reduce the risk of Money Laundering is to conduct electronic checks with our AML partner, Veriphy. Please note we are unable to complete any work on your matter until such time we have satisfied the verification process for every individual. To complete the electronic ID verification, everyone will need to complete a two-step, you must be 18 or over - everyone will need to complete a two-step process and have access to:
- Access to a smartphone or tablet with camera.
- Valid Passport (Any Country) or Valid UK Photocard Driving License (We cannot accept paper licenses.)
- Two separate forms of Address ID for each individual dated within the last 90 days (3 months)
i.e. Utility Bill, Bank Statement, Letter from Government Body/Organisation.
If you do not have access to a smartphone/tablet or don’t have a Passport/Driving License or are under 18, you will need to verify your ID in person. Both processes are detailed overleaf along with acceptable forms of ID.
1.2 Verifying your Identity electronically
1. First, we need to know some basic information about everyone, and you’ll need to provide us with two letters addressed to you at your home address (this helps us to prove you are). We need to know:
a. Your full name, your current address (and your previous if you have moved in the last 12 months or are not yet registered for banking and utilities at your new address) date of birth, contact telephone, email address and your National Insurance number.
b. You need to provide us with two letters addressed to you at home in the last 3 months (Address ID) to help prove you live at the address and are who you say you are.
The letter must be issued by a recognised entity such as a Bank, Utility company, Council or Government Department or a company regulated by the Financial Conduct Authority.
The letters must contain:
i. Your name
iii. Date of issue (must be less than 90 days/3 months)
iv. Name/logo of issuing entity
We understand a lot of clients receive paperless statements and bills, in this instance we recommend logging onto online banking and downloading a statement or sending us recently emailed Utility (Gas/Water/Electricity/TV/Broadband/Phone) bill.
There are two ways you can give us this information:
a. The quickest and easiest way to do this is via our website.
Visit www.thurstanhoskin.co.uk/id-upload and follow the instructions, you will need to have two scanned or downloaded Address IDs to send to us as PDF or JPEG files.
i. If you require more, please let us know and we will send you some or alternatively you can use a mix of paper forms and digital uploads via the website.
2. Once returned you will receive a text and email notification from our Photo ID partner Veriphy, this may take up to 14 business days but usually arrives within a week. You will need your valid UK Photocard Driving license or Passport (any country) to hand to complete the check. It will ask you to take a photo of your ID and take a live selfie, so, you must have a smartphone or tablet with a camera.
Click the link from the email or text and follow the instructions on the webpage, you can check the site is secure by looking for the padlock in the URL bar. The link will be followed by a combination of letters, numbers, and dashes after the =
1.3.1 Verifying your Identity in-person (18+)
If you do not have a smartphone/tablet or Passport/Driving License, you will need to verify your ID in-person at our Redruth office, please still complete and return the form overleaf but tick the box for in-person ID verification. Our Redruth reception is open Monday – Friday, 9.00 am – 5.15 pm. If you wish to present your ID to our St Agnes or Hayle office, you will need to telephone and book an appointment in advance to ensure there is someone available to certify the documents.
Each client who chooses to verify their ID in-person at our office will need to present their own set of ID, we cannot accept your ID if someone else brings it into our office. You will need to bring the following documents.
- Valid photographic ID – see acceptable forms of ID below
- Two separate forms of Address ID – see acceptable forms of ID below
1.3.2 Verifying your Identity in-person (Under 18s)
Under 18s need to verify their identity in-person with their Parent/Guardian present. If available, we will need to see a form of official Photo ID such as Passport, Provisional Driving License or PASS stamped Photo ID card - School & Bus pass ID’s are not acceptable.
We will also require a certified copy of the Birth certificate (we can create one if you have the original) & two copies of Address ID. We would recommend School/College letters or bank letters as Address ID, we could also accept letters from NS&I Premium bonds, If you are struggling to collate any of the required documents please check the help section on the next page.
1.3.3 Acceptable forms of Photographic ID
Acceptable photo ID – Must be in date
- Photo card driving license issued by the UK DVLA (We do not accept paper licenses)
- Passport (any county)
- Biometric residence permit (issued by UK or EU country)
- UK issued PASS stamped ID card (Citizen Card or Post Office ID)
- UK photocard bus pass or blue parking badge (both sides)
- UK Firearms or Military photo ID card
- CSCS Blue or above
PLEASE NOTE: Only a UK/EU Photocard Driving License OR a Passport issued by ANY country can be used for the electronic verification process. If you do not have either of these, you will need to confirm your ID in-person as detailed above.
1.3.4 Address ID - Must be dated in the last 90 days
- Must contain clients name, address & logo or name of issuing entity
- Bank Statement/Credit Statement
- Utility Bill (Gas/Water/Electric/TV/Broadband)
- Council Tax letter
- HMRC, DWP, or other local authority/government department
PLEASE NOTE: If you receive paperless statements, we can accept downloaded and printed copies
If you are struggling to obtain any of the required ID documents, please check the next page for a help list or contact us on 01209 213 646.
1.4 Help sheet
We understand there may be some circumstances where clients, particularly our elderly clients and those under 18, do not have any form of valid Photo ID and/or Address ID.
I Have no Valid Photo ID
- If you have an old Photo ID document which expired less than 12 months ago but the details are all correct this can be provided but we will require an explanation as to why the document has not been renewed.
- The Post Office & Citizen Card both offer a service for individuals with no form of Photo ID to obtain one, it costs £15. You can ask in your local Post office or read more and apply online, both of these cards are acceptable forms of Photo ID anywhere in the UK. - https://www.postoffice.co.uk/identity/pass-card https://www.citizencard.com/apply-for-a-uk-id-card-online
Clients in Care homes
- For clients in care homes who do not have any form of Photo ID we can accept a signed letter from the manager of the care home confirming the resident’s identity and residence, this could also be backed up from a letter by their GP or other medical professional.
- For elderly clients who do not have any form of Photo ID we can accept a signed letter from their GP, other medical professional, or Bank Branch Manager confirming their identity and/or address.
- Many schools and colleges have discount codes and partnerships with Citizen Card meaning you can get a free Photo ID even if you don’t have any other Photo ID to prove your identity, see the I Have no Photo ID section above.
I have no Address ID
- If you receive paperless bills and statements we can accept digital copies emailed or downloaded from your online accounts. The easiest way to give us these is by completing the electronic ID form on our website www.thurstanhoskin.co.uk/id-upload
3. Client basic details form
As detailed in above, you need to provide us with your details and the details of anyone involved with your matter.
The quickest and easiest way to do this is via our website www.thurstanhoskin.co.uk/id-upload
Alternatively you can download the paper forms and return them by post or hand to any of our offices. you can also call us on 01209 213 646 to request paper forms be sent to your home address or to be made available for collection from our Redruth or Hayle offices.
4. Enhanced ID Check.
There may be some instances where you have presented ID in person at our office or have completed an electronic check that we may need to complete a further check, there is no need to be alarmed this is standard practice, we must randomly select matters for this process - you have not been singled out.
We will always notify you by email or telephone of this requirement, generally, this will be via email from one of our admin assistants, they will always copy in the individual dealing with your matter and it will include your unique matter number in the email so you know its genuine, the email will detail what you need to do in order to complete the enhanced check - until you have completed it we wil be unable to progress work on your matter.
Attached to the email will be a document detailing the process, you can also download it below.
BELOW THIS POINT IS THE TERMS FOR ALL INSTRUCTIONS PRIOR TO THE 1ST SEPTEMBER 2023. FOR ALL INSTRUCTIONS ON/AFTER
1ST SEPTEMBER 2023 PLEASE SEE SECTION 1
5. OLD - Money Laundering and Identification Regulations - EFFECTIVE ON ALL INSTRUCTIONS UP TO AND INCLUDING 31ST AUGUST 2023
WE ARE GIVING ALL INSTRUCTIONS PRIOR TO 1ST SEPTEMBER 2023 A GRACE PERIOD TO PROVIDE ID DOCUMENTS IN LINE WITH OUR OLD POLICY DETAILED BELOW.
ALL INSTRUCTIONS PRIOR TO 1ST SEPTEMBER 2023 WILL NEED TO PROVIDE SUFFICIENT DOCUMENTATION AS DETAILED IN THIS POLICY BEFORE 5PM ON FRIDAY 15TH DECEMBER 2023.
ALL MATTERS AFTER THIS TIME, REGARDLESS OF INSTRUCTION DATE WILL BE SUBJECT TO THE NEW REGULATIONS AS DETAILED AT THE TOP OF THIS DOCUMENT IN SECTION 1
In light of the restrictions on movement by the Coronavirus outbreak, we have introduced some amendments to our standard anti-money laundering procedures
Money Laundering Precautions
1. We are required by law to have procedures in place to minimise the risk of money laundering within transactions we carry out, to do this we carry out AML (Anti Money Laundering) Checks on each client involved with the matter, these checks must be completed and verified before work can be undertaken.
2. One way we minimise the risk of money laundering is by knowing where funds are coming from - because of this our preferred method of receiving payment is via bank transfer or debit / credit card. If payment or funds for a transaction are coming from someone other than a named client or registered business, please make us aware of this as early as possible as we will need to carry out additional AML checks on the payee.
3. In the same way if funds are owed to you as a client or a business on your behalf, we usually do this by way of bank transfer, speak to us if this will cause any issues.
4. If we suspect that funds large or small being used for a transaction have come from proceeds of crime, we have an obligation to report this to the NCA (National Crime Agency) this may result in police and / or HMRC (HM Revenue & Customs) investigation; If you are concerned about how this may affect you, please speak with us.
Verifying your identity with us
The main way we reduce money laundering risks is by conducting electronic checks, to do this we require basic information about each individual in the matter alongside one form of Photographic ID and two forms of Address ID. We will need to know your full name, date of birth, current address, contact telephone number and (if you know it) your National Insurance number. Please also make us aware if you have moved house in the last 12 months as this could affect the check.
We ask clients to produce ID in person at one of our offices, however we understand that this isn’t always possible. Listed overleaf is a comprehensive list of all acceptable forms of ID, if you are unable to present yourself at one of our offices, we can accept your ID electronically via one of the below listed methods please see the last page for more information on this.
- Facebook Messenger
If you are attending the office in person, please ensure each individual attends, to accept Photographic ID we MUST confirm likeness to the picture on the document.
We also have a mobile ID check option available, to do this you will need a smartphone with a working camera, you will receive a text and email with a link to upload your ID, please ask the person dealing with your matter if you would like to use this service.
Alongside your basic details we will require the following forms of ID for each individual in the matter.
One form of Photographic ID (GROUP A)
AND one letter issued by a Bank, Council / Government department or Utility Bill (GROUP C)
One form of Photographic ID (GROUP B)
AND two letters by different organisations (GROUP C)
GROUP A – Must be valid and must display your current address
Photo card driving license issued by the UK DVLA (We do not accept paper licenses)
Signed national identity card issued by an EU government
GROUP B – Must be valid
Passport (any nationality)
UK photo card bus pass or UK blue parking badge (both sides)
UK issued PASS stamped card
GROUP C – Must be dated in the last 90 days (3 months)
Council Tax letter
Bank or building society statement
Utility bill (Gas / Electric/ Water / TV / Phone)
Credit card statement
HMRC, DWP, or other local authority / government department letter
Please note that we CANNOT proceed with the matter until such time as we have received sufficient proof of your identity.
If you are sending us the documents electronically this can be in either JPEG or PDF form, please see overleaf for the requirements of the pictures. If these are not followed, we will not be able to complete the check without asking you for additional photographs.
When emailing the documents please email them to email@example.com (or the person dealing with your matter) along with your basic details (mentioned on the previous page)
In all other instances please contact our reception or the person dealing with your matter to let them know how you intend to provide ID documents. For example, if you have requested to send us photos via WhatsApp the receptionist will need the mobile number associated with your account, a member of our AML team will then create a secure chatroom for you to send your documents to us.
Limited Companies & Businesses
We carry out our own internal companies’ house searches when acting on behalf of a business, but in addition we are required to carry out checks on each director of the company in the method stated above.
Photo requirements for sending Identification documents electronically
Group A & B
1. It is important that in the photo we can clearly read all parts of the driving license or passport - It must be valid and in date
- If we cannot read the passports FULL MRZ we cannot complete the check
- If sending an EU Residence permit / Identity card please send a photograph of BOTH sides
2. Please ensure you can clearly see all four corners of the document.
3. You MUST also send a second photo of this document held next to your face so we can verify the ID is yours and carry out a likeness check
1. It is important that in the photo we can clearly read your address, the date of issue (which must be no more than 3 months old) and the logo or address of the issuer (i.e. Cornwall Council, a Bank or government organisation etc.)
- You don’t need to show this next to your face.
PLEASE DOWNLOAD THE HELP SHEET FOR MORE GUIDANCE ON WHAT TO DO