Summary
• All retail customers processing transactions need to register and provide ID/POA for transactions above £800
• All Corporate/MSB customers need to register before the first transaction
• Staff members should report any suspicious transaction to MLRO (but must avoid ‘tipping off’ the customer)
• If this is not possible, all suspicious transactions to be reported to the MLRO as soon as is possible after they have taken place
• MLRO will file a report to SOCA on all transactions he judges suspicious
• All records kept for a minimum of 5 years from the date of the customer’s last transaction
• Personal liability under the law for ‘turning a blind eye’ (i.e. 'wilful blindness') where it should be obvious to employee that money laundering activity may be in process
• Ignorance of the law is no defence
This document is prepared in the English language and not withstanding its translation into any other language, the English version shall be the definitive version, which shall be referred to for all legal purposes.
Signed for and on behalf of Boyare Ltd
Signed………………………………. Date…………………………
Signed for and on behalf of ___________________________________Employee
Signed………………………………. Date…………………………
(Appendix i)
Registration form– private clients (Part 1)
Customer Name
Address
Town
Postcode
Date of birth / Place of birth
Please provide one proof of ID
UK Passport Passport Number:
Date of expiry:
UK Driving licence Number:
Date of expiry:
Other ID Number:
Date of expiry:
Please provide one proof of address (Note: proof of address must be no more than 3 months old)
Telephone bill (not mobile bill)
Gas bill
Electricity bill
Council Tax statement
Bank statement
Other
What it the purpose of the MT transactions you will carry out with our Company? Family support
Health costs
Education costs
Property purchase
Other
What is the source of funds for MT transactions? Work
Savings
Benefit
Gift
Other
How often will you be sending money through the Company? Weekly
Monthly
Other
How much money you expect you will send each time?
Employers name
Employers address
How much is your annual income?
Please tick one of the following I will be sending my own money only'
I will be sending money on behalf of others'
Have you or any members of your family worked outside the UK at any time in the last 12 months? If YES, please give details of your/their job NO
YES - The job they did was?
Registration form– private clients (Part 2)
Please give names and addresses of individuals to whom you will send transactions to. i)
ii)
iii)
iv)
v)
I confirm that the information provided is accurate to the best of my ability. I undertake to inform you within 30 days if there are any change in the information above'
Signed:
(Appendix ii)
Verifying ID – acceptable proofs of identity
At least one of the following ORIGINAL documents:
• Current signed passport
• National ID card
• EEA national identity card
• Current UK issued travel document
• Home Office Immigration and Nationality Directorate application card
• Full UK driving licence
• UK provisional driving licence (photocard and counterpart only)
• Firearms certificate
• Asylum seekers documents (SAL1 or SAL2), and only if issued before 31/1/2002
Please note: if the customer does not present a document bearing a photograph, he/she needs to provide a passport size photograph
Proof of address
At least one of the following ORIGINAL documents issued within the last 3 months showing the customer’s name and current address:
• Utility bill (mobile telephone bills are NOT acceptable)
• Bank, building society or credit card statement
• Driving licence (if not used as proof of ID)
• Council tax bill/mortgage statement
• Benefits/pension book showing current address
• Inland Revenue correspondence
• Inland Revenue correspondence
• An official letter from a third party (e.g. employer, solicitor) confirming address may be considered
Other forms of ID/proof of address may be acceptable, but require sign off by MLRO
Identification - What checks should be made on customer ID evidence given?
• check any photographs for true likeness
• check the date of birth compared to the customer’s apparent age
• compare spelling of names and addresses on different identification documents
• compare the customer’s signature with signatures included in the identification evidence.
• check for the authenticity of the ID provided as there are lots of counterfeit passports, driving licenses and asylum seeker documents in circulation.
(Appendix iii) Corporate/MSB Registration form – Application for business
Company Name
Registration number (Companies House):
MSB Number
Date of initial registration:
Renewal date:
Registered address
Business address
Names of all Directors:
Names of all business owners owning more than 25%
Names of individuals authorised to represent the Company
Turnover of the business
Number of employees
How long has business been operational?
To substantiate the information above we provide at least one of the following:
• Company Registration
• Extract from appropriate company register
• Certificate of Incorporation (certified by lawyer/accountant
• Certificate of Incorporation (certified by lawyer/accountant)
• Copy of memorandum and articles (certified by lawyer/accountant)
• Letter on company letterhead confirming who is authorised to represent the company (must be signed by at least two directors)
• Certified copy of ID/proof of address for person(s) authorised to represent the company
MSB registration
• Copy of MSB registration certificate
• Copy of confirmation from HMRC that owners/directors of MSB are ‘fit and proper’
• Copy of AML manual (including confirmation of MLRO)
What is the estimated volume of transactions in £ Sterling Monthly
Annual
What is the estimated number of transactions? Monthly
Annual
What is the source of funds?
What is the purpose of transactions?
Are there any transactions which are processed which are out of the ordinary or otherwise different from the typical transaction profile?
I confirm that the information provided is accurate to the best of my ability. I undertake to inform you within 30 days if there is any
Signed: Date:
(Appendix iv) Originating MSB partners
Name MSB number MSB Registration – expiry date Daily transaction volumes Number of individual transactions (daily) Bank deposit / Cash deposit
