For Adviser use only. AML Requirements for Trusts with Individual Trustees

Transcription

1 For Adviser use only AML Requirements for Trusts with Individual Trustees

2 > Please note PIA reserves the right to request additional information and documentation as required Documentation quality The 3 C s > Clear: All copy documentation that is sent in to us must be legible and complete. The entire document must be provided and any photo ID must be clearly visible. PIA reserves the right to reject and request new copies if the documentation received is of substandard quality > Current: All forms of ID need to be in date and all bills, statements etc need to be dated within the last 6 months on headed paper > Certified: All copy documentation listed in this guide and that is submitted must be certified as true copies What is a certified document? > Includes a statement such as This document is a true and accurate copy of the original seen before me on DD/MM/YYYY or if natural person that it is a true and accurate likeness or words to that effect and the certifier s name is clearly shown in block capitals along with their signature; > The certification must be signed, dated and where available a stamp should be used by the certifier; > When certifying documents, the certifier must not be a close family member or have any perceived, potential or apparent conflicts of interest with the customer. > Who can certify: Financial Advisers Regulated Financial or Credit Institution including Intermediaries Commissioners for Oaths Justice of the Peace Notaries Public/Practising Solicitors Practising Chartered & Certified Public Accountants Embassy/Consular Staff Police Officers Source of Wealth Confirmation of source of wealth will be required for all applications. PIA is required under Irish Law to understand how the applicant has accumulated the funds intended for investment. Source of Wealth describes the activities that have generated the applicant s funds and Confirmation of the Source of Wealth will be required. In certain cases, additional verification of Source of Wealth including documentary evidence will be required, which must be original or certified documents. Politically Exposed Persons (PEP s) UK domiciled PEPs would be classified as domestic PEPs in the UK. However, under Irish law these PEPs are outside the state and they would be classified as foreign PEPs. Therefore verification documentation will be required as per the applicant type. AML Requirements Guide 2

3 1. AML Requirements for Trusts Trusts can be complex structures and in principle it is PIA s policy to identify and verify not only the trust itself but the relevant parties connected with the trust. This includes the following: > The Trust itself. > All Trustees whether they are corporate entities or individuals. > Parties holding beneficial interest in the Trust including Beneficial Owners/Beneficiaries. > Where deemed necessary any other party connected to the Trust particularly where another entity is responsible for carrying out a specific function of the trust. Trust Type Documentation Required Trusts > Certified Copy of the Trust Deed and supplemental Trust Deeds or equivalent constitutive documents detailing purpose and structure of the Trust and details of the Authorized signers. > Certified Copy of the Authorized Signatories list (required where signatories are not identified in the trust deed or where the signatures have not been provided) > All Beneficial owners/shareholders are to be identified on the Application form or Declaration of Beneficial Ownership form. The information required to identity is; Full Name Full Residential Address Date of Birth > Customer Due Diligence (CDD) for all Trustees (As per Section 2 below). > CDD for any Beneficial owner/shareholders with a Shareholding/Interest of 25% or more holding of the Trust s Assets (as per Section 2 below) Helpful Hints: We always need CDD for beneficial owners with an interest of 25% or more in the contract this always has to be a natural person AML Requirements Guide 3

4 2. Additional AML Requirements for Individuals (Trusts) 2.1 Standard Requirements 1 x Proof of Identity Current Valid Passport with clear photograph and signature (Must be in date) Current Valid Photo Driving Licence with photograph and signature from UK, or EU/EEA Member State, Channel Islands and the Isle of Man (Must be in date) Current Valid State ID Card from an EU/EEA Member State (Must be in date) 1 x Proof of Address : Note : PO Box addresses not acceptable > Bank/Building Society/Credit Card Statement on headed paper clearly detailing the name and current address, dated within 6 months of the submission date. > We will accept statements where the transactions and/or balances are redacted (up to six months old) > Utility Bill on headed paper clearly detailing current name and address (up to six months old) including TV Licence Bill for UK residents only > Current Driving Licence (Photo or non-photo) detailing name and address from UK or EU/EEA Member State and in date at the time of receipt (can only be used as address verification where it has not been used to verify identity); > Current State ID cards from an EU member state detailing name and current address (can only be used as address verification where it has not been used to verify identity > Local Authority Tax Bill for the current year or a National Tax Bill for the current year including Notice of Coding, where this is issued annually then it is acceptable even if it is over 6 months old provided it relates to the current year. > Mortgage Statement or Insurance Statement on headed paper detailing name and address (issued within the last 12 months) from a regulated institution within the EEA or EU Member State. Remember the 3 C s: All ID must be Clear, Current and Certified. Helpful Hints: If funds are being received from a joint bank account we will require personal identification and address verification for both joint account holders All Address ID needs to be dated within the last 6 months and on headed paper All four corners of any ID must be visible including any reference numbers Send in a bank statement with a bank logo and header to cover both address ID and bank a/c verification AML Requirements Guide 4

5 2.2 If a customer can t provide one of the above The below table gives guidelines of alternative documents that can be used to verify the identity and address in circumstances where prospective customer cannot, for justifiable reasons meet the standard identification and verification requirements above: Customer Scenario Client resides in a care home Customer does not have the required standard documentation Acceptable Documents Please obtain a letter from the Care Home manager confirming the name, date of birth and current address of the client (the care home address). This letter must be on headed paper. A written explanation is required giving a valid reason why standard documentation cannot be provided. 2 certified alternative documents from the list below (you may choose a combination of any 2 documents to satisfy the replacement of one standard proof of identity or one standard address requirement). Out of date passport Old style driving licence P60 Birth Cert Marriage Cert Decree Nisi Bus Pass Pension statement Letter from Dept of work and pensions Letter from solicitor confirming name and date of birth of client Council Tax bill for current year Record of home visit (Date of Visit should be within 6 Months of the Application date for UK, Guernsey, Jersey and Isle of Man only) Notice of coding AML Requirements Guide 5

6 The registered office of Prudential International is in Ireland at Montague House, Adelaide Road, Dublin 2. Prudential International is a marketing name of Prudential International Assurance plc. Registration No Telephone number If the Company should become unable to meet its liabilities, the Financial Services Compensation Scheme will protect eligible policyholders habitually resident in the UK when their contract starts, with effect from 1 December This protection does not extend to externally-linked investments. Prudential International Assurance plc is authorised by the Central Bank of Ireland and is subject to limited regulation by the Financial Services Authority for UK business. Details on the extent of our regulation by the Financial Services Authority are available from us on request. PRUAG /2016