ID Documentation for new clients
When we appoint a new client we routinely do the following id checks:
Check companies house website for registration details
Obtain appointment report & if available annual return
Get a copy of utility bill for business address
Get a copy of photo driving licence or passport & home utility bill for each director (even if not acting for personally)
Do we need photo id for all of the directors in every instance, what if we are not acting for them? What if director supplies home utility bill & copy of paper driving licence as often happens even though we ask for photo id (we are not exactly starting our relationship in the most positive way if we then have to go back and ask for further photo id)
We also act for a substantial number of charities & go through same procedures obtaining a list of trustees / directors from Charity Commission or Companies House
Do we need to obtain photo id & home utility bill for the trustees & if so for which trustees? All of them, those that can sign cheques, or those that we liaise with? Do we need to regularly update this as new trustees are appointed?
We always complete a decision to accept appointment form for new clients which considers risks including ML risks and we have never appointed a client where we have had any ML concerns, so for our new clients the risks are minimal & consequently we only want to do the minimum checks necessary (to stand up to ICAEW scrutiny) rather than go overboard
What are your views?