You are required to take all reasonable and proper precautions to verify the identity of your client as a Will writer, and also to verify the instructions you take from that person. This is in accordance with the ‘Money Laundering Regulations 2007’.
Before proceeding with taking instructions from the client, you should obtain two forms of ‘Identification’ (ID) from each of your clients. One must be ‘Photo ID’ and the other must be a ‘Proof of address’.
You should obtain one document from list A and one document from list B:
List A – Identity Documents
- Current ‘Signed passport’
- Valid UK ‘Photograph driving licence’
- EEA ‘Member state identity card’
List B – Proof of Address
- Valid UK/EU/EEA ‘Drivers Licence’ – if not used from List A
- ‘Bank’ or ‘Building society’ statement
- ‘Utility’ bill
- ‘Council tax bill’
- ‘Mortgage statement’
All documents produced for proof of address must be no older than ‘Three months’ and must have the ‘Current address’. A copy of the ID should then be kept with the file so you can show you followed a sequence of protocols to identify the client before taking instructions.
With the current situation (Covid 19 Pandemic) and remote instruction taking, we understand and appreciate it will not be easy to obtain a copy of the ID. Therefore:
1) You should ask the client to send you a ‘Photo of their ID’ prior to the meeting.
2) Before the meeting commences, ask to see the ID which the client can then hold up to the camera.
If you require assistance please do not hesitate to contact us.