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 Template AML Client Identification Checklist is designed for use by a low risk business that wishes to check the identity of a new client or customer for anti-money laundering purposes. The template contains a checklist for individuals followed by one for corporate entities.

A business that is 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 their clients/customers. A low risk business is a business which is not regulated under these Regulations and therefore is not required to carry out this identification and verification. However, as a matter of good corporate governance, it is sensible for all businesses to consider having policies and procedures in place to identify and minimise the risk of money laundering within their organisation; including checking a client’s identity.

This form prompts the company to check a client’s/customer’s documents to prove their name and address or corporate identity. A list of acceptable documents appears in the form. The company then assesses the level of risk and records this on the form.

This form is suitable for simple due diligence. Enhanced due diligence may need to be undertaken for high risk clients/customers.

This template should be read in conjunction with the AML policy and Company Wide Risk Assessment. If you are unsure as to the risks your business may be exposed to or how to complete this template, you should seek professional advice.

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