Proving Your Identity

Why do we ask you to prove your identity and address?

Since 1994 it has been a legal requirement for all providers of financial products and services to have procedures in place to stop criminals laundering their ‘dirty’ money (‘Money Laundering’). These procedures include us obtaining proof of your identity, address, date of birth, nationality and country of residence - in order to establish that you are who you say you are. In some cases, we will also require information on how an account will be operated and where funds to operate the account have come from.

The Financial Conduct Authority (FCA) has published a consumer fact-sheet detailing some information about the fight against money laundering. The fact-sheet is available on the FCA's web site: http://righttrack.org.uk/FSA Identity check leaflet.pdf

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What is money laundering?

Money laundering is the method criminals use to disguise the money they make from their crimes. Criminals have to disguise the source of their ill-gotten gains to prevent money or assets from being traced back to them and seized. Criminals want to get their ‘dirty’ money into the financial system so that it seems ‘clean’ and harder to trace. They can then use this clean money to spend on themselves, or use it to fund more crime and terrorism.

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How does this affect me?

To launder money criminals will usually try to apply and open an account using a false identity.

Using a false identity and address might make it harder for the authorities to track down criminals and their ill-gotten gains during an investigation. For this reason we are required by law to verify your identity and address. We are permitted to verify your identity and address in a number of different ways, depending partly upon the way the account is structured and used. Checks will be made regardless of the sums concerned. The fact that these checks are carried out does not mean you are under suspicion - the only way to stop the criminals is to make checks on everyone.

Until these checks have been made and your identity and address verified we will be unable to activate your account.

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What proof will be asked for?

It might vary depending upon the type of account you want to open and how that account is used. Please read the details of the requirements for the particular type of account below. In some cases we may ask you for additional proof if the information or proof you have so far provided is incomplete or unsatisfactory. Similarly, if we offer you (or you ask us) to provide an additional service, we might be required to ask you to provide additional proof even though you already have an activated account.

In cases where an account is operated by an Authorised Representative, that representative will need proof of their identity in accordance with that required for those acting as an Authorised Representative below.

In cases where you need to provide documents such as copies of passports or identity cards, memorandum and articles of association we will require certified copies. Details of certification is provided below.

In cases where you send us a cheque to fund your account or pay other charges you may send a personal cheque drawn in your or a joint name. Cheques drawn on third party will not be accepted. Details of our requirements for cheques is provided below.

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Proof for a private individual(s) opening an account

Full Verification Method

Evidence of identity and address

We will require you to provide one item of proof of personal identity from List A and one different item of proof of address from List B. Evidence of identity and address must match the registered details provided by you when applying for the account.

The same piece of evidence may not be used as both evidence of personal identity and address. Therefore even if a photocard style driving licence contains your address it cannot be used as both evidence of identity and address at the same time. A separate item of evidence of address would be required.

Additional Requirements

In addition to providing an item from List A and List B we will require you to provide a funding cheque from the Bank or Building Society account you have registered with us to maintain the dealing account. Additionally we will need to verify the details you have already provided with reference to an electronic source such as the Electoral Roll.

List A - Acceptable items of evidence of personal identification - one item required

AND

List B - Acceptable items of evidence of address - one item required

Items marked * must be the original documents (not photocopies) which will be returned to you at your registered address.

To guard against the dangers of postal interception, impersonation and forgeries the items with ** above must be sent to us as a certified copy - please do not send originals of these documents. Copies of documents must be certified as being a true copy of the original seen document and true likeness of the person in the photograph. Certification should be undertaken by a regulated or professional person such as a lawyer, banker, financial intermediary, accountant, teacher, general practitioner, or minister of religion. Each certified copy must be signed by that person, stating their full name, qualification, job title, professional address, telephone number and date of certification. Self certification by the customer or by any relative will not be accepted.

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Certification

Example of certification on a document bearing a photograph

I [enter full name and title of person doing the certification] certify that
this is a true copy and likeness of the original seen by me this [enter date of certification].



[signed]
[qualification and/or job title]
[professional address]
[telephone number]

Example of certification on a document not bearing a photograph

I [enter full name and title of person doing the certification] certify that
this is a true copy of the original seen by me this [enter date of certification].



[signed]
[qualification and/or job title]
[professional address]
[telephone number]

Black & White copies of UK passports

In order to comply with guidance issued by HMSO in respect of copying and certifying UK passports copies must be in black and white so that they cannot be mistaken for an actual passport page.

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Cheques

We are only able to accept personal cheques drawn in your or a joint name. If you cannot send a personal cheque, we will accept a bank draft or building society cheque provided it is accompanied with evidence that the funds have been drawn from your account. We will not accept cheques received or drawn from third parties.

Evidence to accompany bank drafts or building society cheques

Unfortunately we increasingly encounter difficulties in establishing that a bank draft or building society cheque has been drawn on the account of a particular customer. This is in part due to banks and building societies' security controls and their compliance with data protection requirements.

In order to overcome these difficulties, we require evidence that the funds have been drawn from your account and not that of a third party. This may take the form of:

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Proof for Standard accounts

Private Individuals - we will require you to send proof of your identity and address in accordance with that required for private individual(s) full verification method above. If the account is a joint account, both account holders must provide proof.

Companies - we will require you to send proof of the identity of the company and its controllers in accordance that required for Corporate accounts below.

UK Family Trusts - we will require you to send proof of the identity of the beneficiaries and trustees and settlors of property in accordance with that required for UK Family Trusts below.

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Proof for ISA accounts

We require you to send proof of your identity and address in accordance with that required for private individual(s) full verification method above.

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Transfers of ISAs

Existing customers with an active account which has been funded from their personal bank account should not require further verification to activate transferring-in ISA accounts. However to guard against identity fraud we may require additional proof.

New customers must send us a cheque to make an ISA subscription and send us proof of their identity in accordance with that required for private individual(s) full verification method above.

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Proof for Margin accounts

Private Individuals - we will require you to send proof of your identity and address in accordance with that required for private individual(s) full verification method above. If the account is a joint account, both account holders must provide proof.

Companies - we will require you to send proof of the identity of the company and its controllers in accordance that required for Corporate accounts below.

UK Family Trusts - we will require you to send proof of the identity of the beneficiaries and trustees and settlors of property in accordance with that required for UK Family Trusts below.

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Proof for Investment Club accounts

In addition to our requirement that the club’s bank account must be UK based, all members of the club and any authorised representative(s) for the account must provide proof of their identity and address in accordance with that required for private individual(s) full verification method above.

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Proof for Corporate accounts

Listed Public Companies

If the company is quoted on a recognised stock exchange or is a subsidiary under the control of a quoted company then we require you to provide the items of identification in List C.

Non-Listed Companies

If the company is not quoted on a recognised stock exchange we require you to provide the items of identification in List C and List D.

Each principal owner, controller or representative signing on behalf of the company must provide proof of their identity and address in accordance with that required for private individual(s) full verification method above. Corporate owners, controllers or representatives of a subsidiary or affiliate company opening an account must have proof of its identity provided in accordance with this section. For example, a subsidiary company opening a dealing account must provide evidence of itself and its parent company.

List C - Required items of identification for a Corporate entity

List D - Required items of identification for a Corporate entity

OR

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Proof for UK Family Trusts

For straightforward UK family and absolute trusts we require the trustees (or their professional advisors) to provide the following items of identification in List E. Additionally as to proof of identity of the trustees, beneficiaries, and settlors (donors of trust property, if not deceased) and authorised representatives we require proof of personal identity and address in accordance with that required for private individual(s) full verification method and/or corporate entities from List D or FCA Regulated Financial Services Intermediaries, as applicable.

List E - Required items of identification for UK Family Trusts

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Proof for those acting as an Authorised Representative

In addition to verifying the identity of customers, we are also required to verify the identity of all those who have authority over an account. If a customer grants authority over an account under a power of attorney or otherwise (including our Third Party Authorisation form), the authorised representative or attorney-in-fact will be required to provide proof of their identity in accordance with that required for private

individual(s) full verification method or FCA Regulated Financial Services Intermediaries.

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Proof provided by FCA Regulated Financial Services Intermediaries

If an account is introduced to us or traded on a discretionary basis by an FCA authorised entity such as an Independent Financial Advisor (IFA), Fund Manager, Trust Company, SIPP provider, etc. that intermediary may be able to provide us with a Money Laundering Introduction Certificate on behalf of our mutual customer avoiding the need for further verification of identity at the account opening stage. In these cases we only require verifiable evidence of the intermediary’s authorised status.

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