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Client Identification – Unincorporated Associations

The Money Laundering Regulations 2007 oblige solicitors and other professionals to obtain satisfactory evidence of their client’s identity.

To enable us to comply with our due diligence requirements under the Regulations we respectfully request that you provide us with the appropriate forms of ID as set out below.

Key Documentation

ID for two principal controlling parties as set out below

ID for anyone holding over 25% of the associations’ property

If the controlling parties and persons holding over 25% of the associations’ property are regulated professionals

If the controlling parties or persons holding over 25% of the associations’ property are regulated professionals who are subject to a regulatory body (e.g. SRA, FCA, ICAEW, GMC) then you do not need to provide us with any identity documents as listed below. Instead we simply need details of the regulatory body and their professional directory.

If the controlling parties and persons holding over 25% of the associations’ property are NOT regulated professionals, we require the following

To verify name and identity (ONE OF THE FOLLOWING)

Valid passport

Photocard driving licence (provided not used as evidence of address)

National ID card

Firearms and Shotgun certificate

AND,

To verify address (ONE OF THE FOLLOWING)

Utility Bill [mobile phone not sufficient] (no more than 3 months old)

Bank/Building Society/Mortgage statement (no more than 3 months old)

Current Council Tax Bill

Current tenancy agreement

Photocard driving licence (provided not used as evidence of identity)

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National ID card (provided address is shown and not used as evidence of identity)

National Identity card (provided address is shown and not used as evidence of identity)

If the controlling parties or entities holding over 25% of the associations’ property are a company, we will require all of the following

A copy of the Certificate of Incorporation

Memorandum and Articles of Association

A list of the Directors and Shareholders of the company with their names and home addresses (normally contained within the Annual Return)

The three items above are normally filed at Companies House and are available to the public.

ID for at least two directors (unless a sole director) as set out below

ID for any person or corporate entity holding over 25% shares in the company as set out below*

*If a corporate entity has a 25% or more controlling interest in the client company, we must receive all of the documents (as above) for that controlling entity and repeat the process until we reach the ultimate beneficial owners and understand the overall corporate structure.

Certification of Documents

It is a requirement that all forms of ID are certified.

If you intend to visit our offices in the next few days, please bring the forms of ID with you and we will arrange for a copy to be taken and certified.

If you are sending us the above documents then you will need to arrange for a certified copy to be made and send us the original certified version.

The following persons are authorised to certify documents:

- notary republic

- legal professional

- tax adviser or accountant

- insolvency practitioner

- a credit or financial institution

- a post office