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Q & A corner: client due diligence at a distance

17 April 17

Professional Practice advice: acceptable documents when clients are elsewhere

Q. My clients are based down in the south of England and cannot meet me face to face to discuss matters and let me do the normal money laundering checks. They are asking about sending me ID documents for money laundering to let me carry out client due diligence. When I spoke to them they said that they are planning to use the Post Office document-certifying service for certification of documents, rather than send me the originals. Is that acceptable and will that mean I have complied with the Society rules?

A. Although the Post Office service is no doubt very useful for many people, for the purposes of solicitors doing money laundering checks it is not good enough and any ID certified by the Post Office cannot be relied on. Ideally, the client needs to send you the originals of the documents so you can satisfy yourself about their authenticity. If that is not possible, you will need to use the rule which allows you to place reliance on the actions of other “regulated persons”. That would involve your clients going to a local solicitor (or one of the following: regulated accountant, regulated tax adviser, regulated insolvency practitioner, regulated auditor, an authorised credit or financial institution or a consumer credit financial institution), who can examine and certify the documents and allow you to rely on that certification to be comfortable that you have complied with your own obligations.

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