I have someone who was a client until last year and has now just come back (a break of about 6 months).
I looked up the copy of his passport he handed to me first time round, and noticed it expires this week, although technically it is 'current' today!
Should I ask him to send a certified copy of his new passport when received (he cannot now visit me so easily, although he did first time round)? Surely it won't look good for an MLR audit to spot an expired passport on file
Replies (3)
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Stand to be corrected
Unless your policy is to obtain up to date documents for all clients on an ongoing basis - you would need to do this everytime a client moved house, changed supplier of utilities etc which I suspect is overkill (not to mention a huge amount of non-chargeable work) then I would think that his current passport, valid on the date you seen it, would be fine.
Keeping ID up to date
There is an obligation to keep your Customer Due Diligence up to date - see Reg 8 MLR 2007.
But that doesn't mean that you have to re-perform the initial ID checks just because the client's passport is expiring.
If the client changes name (by marriage, for example) then you would need to get some ID for the new name. The same if the client sets up a new company and asks you to act for it (you need to ID the new company).
If the client changes address then I would expect that next time you do a tax return or set of accounts you might see something with the new address on it (a bank statement for example). Keeping a copy of that would be sufficient to confirm the new address.
But everything needs to be on a risk-sensitive basis. Don't break your back chasing paperwork if there is really very little money laundering risk attached to the client.
David