No Original Documents

Past version: effective from 21/10/2015 - 20/10/2015
To view other versions open the versions tab on the right

36. In complying with Rule 8.3.1(1)(a), it may not always be possible to obtain original documents. Where identification documents cannot be obtained in original form, for example because a Relevant Person has no physical contact with the Customer, the Relevant Person should obtain a copy certified as a true copy by a Person of good standing such as a registered lawyer or notary, a chartered accountant, a bank manager, a police officer, an Employee of the Person's embassy or consulate, or other similar Person. The Regulator considers that downloading publicly-available information from an official source (such as a regulator's or other official government website) is sufficient to satisfy the requirements of Rule 8.3.1(1)(a). The Regulator also considers that CDD information and research obtained from a reputable company or information-reporting agency may also be acceptable as a reliable and independent source as would banking references and, on a risk-sensitive basis, information obtained from researching reliable and independent public information found on the internet or on commercial databases.
37. For higher risk situations the Regulator would expect identification information to be independently verified, using both public and non-public sources. For lower risk situations, not all of the relevant identification information would need to be verified.
38. In complying with Rule 8.3.1(1)(b) and (c), a Relevant Person is required to "understand" a Customer's Source of Funds and wealth. This would mean obtaining information from the Customer or from a publicly-available source on the Source of Funds and wealth. For a public company, this might be achieved by looking at their published accounts. For a natural or Legal Person, this might involve including a question on Source of Funds and wealth in an application form or Client questionnaire. Understanding a Customer's Source of Funds and wealth is also important for the purposes of undertaking on-going due diligence under Rule 8.3.1(1)(d).
39. An insurance policy which is similar to a life policy would include life-related protection, or a pension, or investment product which pays out to the policy holder or beneficiary upon a particular event occurring or upon redemption.