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CDD - do you need up-to-date passport?

Do we need current passport if previous one has expired?

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I do my CDD update every 3 years and get copies of any passports that have expired. But is this really necessary?  ATT guidance says that if you verified a passport at outset, then there is no requirement as you have already ID'd an original document. But my AML firm disagree and are saying that you must always hold up-to-date ID.

Can anyone clarify please? Any links to guidance would be welcome.

Thanks

 

Replies (11)

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By Matrix
06th Feb 2020 16:38

What do you mean by your AML firm? I have no idea why you would need up to date id once you have verified someone.

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By fellowcraft
06th Feb 2020 17:02

We use AML software, it was the provider. Yes same here, but looking for something concrete to rely on

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By Wanderer
06th Feb 2020 17:43

Do you take your latest passport into your bank every time you renew it?

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By fellowcraft
06th Feb 2020 20:30

True

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By Paul D Utherone
06th Feb 2020 17:53

It does seem rather pointless. I am always reminded of the Dara O'Briain tale of out of date photo id at the airport on an internal flight:

Security - This ID's expired
DO'B - Yes...but it's still me

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By Roland195
06th Feb 2020 18:23

This is the company selling the software that charges per check telling you this is it?

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By Matrix
06th Feb 2020 20:31

Oh I didn’t know what he meant by AML software, this is a KYC service?

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By fellowcraft
06th Feb 2020 20:29

Nope, I dont use them for ID checks, it's about photo ID only

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By jwgrogan
07th Feb 2020 19:28

When I had an AML inspection by HMRC, the inspector insisted that documents used to confirm ID must always be kept up to date to comply with ongoing monitoring requirements, and that an expired passport did not meet this requirement. I don't think this is what the law actually says, and even if it did I think it is pointless to insist on this. If a client is going to change their identity, they are either going to keep the old one going as well, or they are going to need to send their tax returns in under a new name, in which case I would get need to get a copy of a passport in a new name. Also, I could keep a copy of a passport for 10 years, and not know that the client had changed his name and obtained a new passport after say 1 year, unless they told me. Here is the JMLSG guidance:

Regulation 28(11)(b)
5.3.27
Documents or information obtained for the purposes of applying CDD measures, held about customers, must be kept up to date. Once the identity of a customer has been satisfactorily verified, there is no obligation to re-verify identity (unless doubts arise as to the veracity or adequacy of the evidence previously obtained for the purposes of customer identification); as risk dictates, however, firms must take steps to ensure that they hold appropriate up-to-date information on their customers. A range of trigger events, such as an existing customer applying to open a new account or establish a new relationship, might prompt a firm to seek appropriate evidence.

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By adam.arca
08th Feb 2020 10:29

I'd agree with the general thrust of the responses that, once a client is identified, then they're identified, end of, and there's no definite requirement to re-identify.

That said, personally, last year I was beginning to feel uncomfortable about the age of some of my ID and the fact that my approach had changed over time, so I did have a bit of a campaign to get all my clients to update the ID they had provided and now have a benchmark of nothing earlier than 2019. It also tied in well from an admin POV / convincing clients to co-operate with the issue of new terms of business.

One of the other reasons why I did that was that I had become aware that many solicitors handled CDD differently to accountants. Unlike us with our more general files, they tend to have discrete matters and seem to be asking for CDD every time they open a matter rather than relying on the CDD they have already performed on the same client for an earlier matter. You can see the logic for that in the light of the guidance quoted above.

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By paulwakefield1
10th Feb 2020 08:40

ICAEW course at the end of last year said there was no need to update an expired passport (assuming it was in date when first seen) unless your own risk assessment suggests otherwise.

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