Anti-Money Laundering Client Identification Checklist
This template is an EXAMPLE only and is intended to be a starting point for you to implement the requirements set out in the legislation and guidance. This template is designed for a low risk, unregulated business only. It is not intended to be used for a regulated business or by those involved in advising regulated entities, such as accountants.
This Anti-Money Laundering Client Identification Checklist is designed for use by a low risk business that wants a structured way to check the identity of a new client or customer for anti-money laundering purposes.
What this checklist includes
The checklist includes:
- a checklist for individual clients/customers; and
- a checklist for corporate entities.
Regulated sector and when checks are mandatory
A business regulated under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, must identify and verify its clients/customers.
A low risk business that is not regulated under those Regulations is not required to carry out identification and verification. However, as a matter of good corporate governance, many businesses may still choose to put policies and procedures in place to help identify and minimise money laundering risks, including checking a client’s identity.
How the checklist helps you record your due diligence
The form prompts the company to check documents to evidence a client’s name and address (or corporate identity). It includes a list of acceptable documents and allows the company to assess and record the level of risk.
Simple due diligence and higher risk clients
This checklist is suitable for simple due diligence. Enhanced due diligence may be needed for high risk clients/customers.
Related AML templates
This checklist should be read in conjunction with the Anti-Money Laundering Policy and the Company Wide Anti-Money Laundering Risk Assessment. If you are unsure about the risks your business may be exposed to, or how to complete this checklist, you should seek professional advice.
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