Anti-Money Laundering Client Identification Checklist

A detailed client due diligence (CDD) checklist and record for businesses in the anti-money laundering regulated sector, such as accountants, bookkeepers, tax advisers, insolvency practitioners, trust or company service providers, estate agents and letting agents. It walks you through identifying and verifying the client and its beneficial owners, assessing risk, screening for politically exposed persons (PEPs) and sanctions, deciding whether simplified or enhanced due diligence applies, approving the client, monitoring them and keeping records, in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended (“MLRs”).

• Before taking on any new client or establishing a business relationship
• Before carrying out an occasional transaction at or above the threshold
• When a client’s circumstances change, at periodic reviews, or when you have doubts about information previously obtained
• When you suspect money laundering or terrorist financing, whatever the amount

• Complete one checklist per client (with a separate Part 4 or 5 for each beneficial owner as needed)
• Keep copies of every document seen and the results of electronic checks with the checklist
• Have the checklist reviewed and approved by the person named in your AML policy, and by senior management for high-risk clients and PEPs
• Diary the next review date and follow your firm’s policies, controls and procedures