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What ID is needed for non resident directors?

What ID is needed for non resident directors?

Just undertaken a client file review and we have a UK Ltd company that has just appointed a non resident director to its board.  For AML record keeping, we will request a copy of their passport photo ID, but is there anything else you would normally ask for?  UK resident directors normally provided recent utility bills to confirm their address as well as paasport/driving licence.

Can you please advise?


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17th Jan 2013 13:39


Are you also acting for the director personally (for example are you dealing with his personal tax returns)?

If not, is he a 'beneficial owner' in the context of MLR 2007?

If he is neither a client nor a beneficial owner then you do not need ID from him for MLR purposes.


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17th Jan 2013 14:14

I've just checked MLR 2007...

...given that I do not act for any of the directors of this company personally, my reading suggests only individuals who own or control (directly or indirectly) more than 25% of the shares or voting rights are deemed to be "beneficial owners".  Therefore, in this instance, I will not request it - but will document why I haven't. 


Thank you for your response David, as ever, it is always best to return to the legislation.

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