Money laundering ID problem

Tax Assessments ?

I have come across this problem before.

I suggest two things -

1) Ask the bank for a full list of ID they accept - you might find it quite enlightening, especially the difference between UK citizens (from whom they demand reams of evidence) and overseas visitors (who seem able to open an account almost on demand).

2) Take official HMRC assesments/letters etc as proof of ID. HSBC accepted this as proof of ID for one of our clients in similar circumstances.

Is he on the electoral roll?

Is he on the electoral roll at his home address?  Does he have any credit cards / store cards?  Has he taken out any other form of credit or loan agreement (HP on a car for example)?

Any of these activities will leave some sort of a 'footprint' which can be seen by the bank if they undertake an electronic search for him.

Does he have his birth certificate and anything showing his National Insurance number?

If his mother's bank won't budge go to another bank!

David

ID Cards

David, in the cases we have had the banks wont accept credit cards/store cards as proof of ID.  We even had a bank refuse to accept as proof a credit card that THEY had issued.

They insist of some form of official ID with a photo. Old fashioned paper driving licences are not accepted, photo licences are.

It seems that without photo ID you dont exist.  Call me a conspiracy theorist if you like, but is this all part of the Labour plot to impose ID cards on everyone?  

Proof of ID

I was not meaning that the production of a store or credit card was proof of ID.  I was meaning that if this individual has such a card account it would leave a 'footprint' which would show up on an electronic ID check (as will his entry on the electoral roll).

The banks have voluminous guidance from the Joint Money Laundering Steering Group on compliance with the MLR.  This includes at section 5.3 of part 1 general guidance on initial ID of individuals.

Note this:

"5.3.114 Where an applicant produces non-standard documentation, staff should be discouraged from citing the ML Regulations as an excuse for not opening an account without giving proper consideration to the evidence available, referring up the line for advice as necessary. It may be that at the conclusion of that process a considered judgement may properly be made that the evidence available does not provide a sufficient level of confidence that the applicant is who he claims to be, in which event a decision not to open the account would be fully justified. Firms should bear in mind that the ML Regulations are not explicit as to what is and is not acceptable evidence of identity."

There is a great deal in the guidance about non-standard documents.  This suggests, at para 5.3.74, that

"a government-issued document (without a photograph) which incorporates the customer’s full name, supported by a second document, either government-issued, or issued by a judicial authority, a public sector body or authority, a regulated utility company, or another FSA-regulated firm in the UK financial services sector, or in an equivalent jurisdiction, which incorporates his full name and either his date of birth or his residential address"

should be adequate.

The JMLSG guidance is online at

http://www.jmlsg.org.uk/content/1/c6/01/14/56/Part_I_-_HMT_approved.pdf

It sounds to me like a birth certificate plus a fairly recent credit card account statement (received through the post - not printed off the internet) ought to do the trick.

David

passport

Why not just apply for a passport?

?

Posted by fellowcraft on Sat, 21/11/2009 - 14:39

COST ?

rip-off Britain

Even this is an example of rip-off Britain.

£77.50 compared to C$87 (about £45) for a Canadian passport. 

I stil suspect that the money laundering regulations have more to do with government prying than security.

I think

£77.50 is an outrageous price. I wouldn't be prepared to pay that if I didn't need one, just to open a bank account with an organisation which does not train staff to use their brains and not quote stupid rules and regulations. Thanks David for your input as I am frequently told that this or that can't be done, for various modern day reasons such as ML or the other favourite "Data protection".

I tried sorting out my daughter's mobile phone when it was pinched from her rucksack in the bush in Africa. Unless I could give a crime number or quote which police station it was reported to I was going nowhere fast, and the wonderful insurance WOULD NOT pay. And that was after endless hours of argument about whether anyone would actually speak to me or not. "Why doesn't your daughter ring us?" I was asked............duhhhh.

Excuses

Data Protection - the excuse I hear every day of my life. 

The craziest "excuse" I ever heard was when I was told by someone at a HMRC call centre that they couldnt discuss my tax affair with me because they didnt hold a 64-8 from me authorising them to discuss my affairs with me.  Obviously HMRC have staff in straight jackets answering the phone in their padded rooms.

As for insurance companies - do they ever actually pay out ? 

If you are not meeting them . . .

If you are not meeting the client then a photograph is of no assistance.  But you are not required to have photo proof.  As indicated in this thread you can accept non-photo documents.

Bear in mind the requirement of Reg 14 when dealing with a person whom you do not meet.  In essence this requires a higher level of CDD (normally met by requesting additional documents).

David