The errors here tend to fall into two categories: timing, and content.
The timing problem arises when you fail to obtain ID quickly enough. The whole point of the legislation is to identify proceeds of crime and those dealing with such funds, and to take action against them. If you fail to identify your clients early enough, you risk becoming part of the problem and handling ‘dirty’ funds without permission. You should identify your clients before you accept an appointment if possible and if you still haven’t done this within 7 days of your appointment you need to consider stopping work as you are at risk.
To verify the ID of individuals you will normally need photographic ID and evidence of their address. The photographic ID on your file should be clear. We see too many instances where the photocopy is so dark that it is impossible to identify the person from it. The copy should also be certified. If you copy the original yourself, then you need to confirm that it is a true likeness. By dating that certification you are also providing evidence as to when you verified the ID. If you are provided with a copy then it should be certified by a professional who knows the client well enough to be able to confirm the likeness. Finally, the evidence of address has to be recent enough to be reliable. As a guide, if the utility bill is less than 3 months old it is probably adequate.
