Anti-Money Laundering Requirements

Transcription

1 Anti-Money Laundering Requirements To be used by IFAs within the EU, Channel Islands, Isle of Man, Iceland and Gibraltar PRODUCT COMPARISON New Business Checklist Friends Provident International offers UK, Guernsey and Isle of Man law products and as such we are expected to meet anti money laundering and the combating of terrorist financing requirements set by the individual regulators in the UK, Guernsey and the Isle of Man. We recognise the difficulties this can pose to our IFAs, your business and where possible, we do try to adopt a singular consistent approach. How to use this checklist This checklist should only be used by IFAs regulated in the UK, EU, Channel Islands, Isle of Man, Iceland and Gibraltar. The purpose of the checklist is to establish the Anti-Money Laundering requirements and the acceptable documents for verification of identity and address for policies issued by our UK, Guernsey and Isle of Man operations. The related products are: UK Business Guernsey Business Isle of Man Business Term Assurance International Investment Bond Reserve Critical Illness Plan International Savings Plan Elite Versatile Investment Plan Guernsey International Pension Plan Zenith Directions Premier Income Protection Plan Premier Ultra Homebuyer Plus Plan International Protector AlphaSave

2 1 Proof of Address The following proof of address documents must be valid within the last 3 months or the latest available Proof of ownership of a property Proof of rental of residential address A gas/water/electricity utility bill A telephone bill (landline bills only, mobile phone bills are not acceptable) Entries in a local published telephone directory can be accepted (note: Internet enquiries are not acceptable) Bank/Credit card statement quoting a full residential address. It must be clearly printed that it is a bank/credit card statement and make reference to an account in the name of the applicant (note: Store cards and Point cards are not acceptable. Bank statements printed off the Internet are not acceptable). If the statement only states a PO Box address, completion of a Verification of PO Box Address form must be submitted with the original certified true copy of the statement (if there is no other proof of residential address available). Record of a home visit Investment/Insurance documentation issued by a recognised lender in the UK Mortgage statement A letter from the employer of the applicant confirming the residential address. Where the applicant has accompanied a partner or spouse on a work assignment contract, and they are also an applicant, an employer may confirm the address of a non-employee where a relationship is detailed. The employer s letter should state and show the following: Appear on the company letterhead and include the telephone / fax and registered address If a company stamp is used, the company name must be clear and include telephone / fax and registered address The person signing the letter must be in a senior position The company position of the person signing the letter must be clearly stated The letter must be dated The full name(s) of the applicant(s) must be stated. Government-issued National ID card quoting a full residential address Page 2

3 2 Proof of Address unavailable FPI are required to confirm the residential address of applicants. Where suitable documentary evidence is not obtainable, we require a clear explanation of why it is not possible to verify residential address. The following documents should be used to explain: UAE Residency Visa: The residency visa must be valid and the passport number on the visa must match the applicant s passport, provided to evidence identity. FPI form: Verification of PO Box Address / Confirmation of residential address AND one of the following: A certified copy of the applicant s bank statement showing a PO Box address For UAE - Residency visa page (see comments) will be accepted instead of a bank statement For Qatar Residency Permit (see comments) will be accepted instead of a bank statement Qatar Residency Visa: The visa must be current, with the applicant s name and the Government reference numbers clearly visible. 3 Proof of Identity Passport National ID Card Drivers license Armed forces ID Card, unless accompanied by another formal document, unless accompanied by another formal document All documents must show the following: Unique reference number Photograph Issue date Expiry date Forename and surname Signature For Isle of Man contracts: Where a passport and national ID card does not exist, two formal documents may be accepted to prove identity. Examples of a formal document are an income tax return or a document with a unique reference number issued by a government authority 4 Source of Wealth Source of wealth evidence is required if premiums are equal to or in excess of 200,000/US$400,000 single premium and 24,000/US$48,000 per annum regular premium * Please refer to the Source of Wealth table for acceptable documentation * Confirmation of source of wealth is required only for UK single premium contracts and topups (evidence not required, not applicable to Guernsey contracts) 5 Introducer Certificate a) Verification of Identity and Source of Funds (VISF) b) UK Identity Verification Certificate (FSA regulated IFAs only) UK and GUERNSEY only An introducer certificate must be completed for each applicant, premium payer and trustee, by either completing a VISF or UK ID Verification Certificate (FSA regulated IFAs only). Certified documentary evidence is not required for IFAs regulated in the UK, EU, Channel Islands, Iceland and Gibraltar. Where an employer / company is an applicant or premium payer please refer to Section 9 Page 3

4 6 Small Premium Exemption UK and GUERNSEY The Small Premium Exemption can be claimed where the premium (and any existing premiums from in-force policies the customer has with FP) does not exceed 50 per month or 600 per annum (or equivalent in USD, EUR or AED). ISLE OF MAN The Small Premium Exemption can be claimed where the premium (and any existing premiums from in-force policies the customer has with FPIL) does not exceed EUR 250 per month or EUR 3000 per annum (or equivalent in GBP, USD or AED). International Protector only 7 Source of Funds as evidence UK and GUERNSEY only The Source of Funds as Evidence concession can be claimed on the VISF to verify the identity of the customer in place of a full verification check. The following conditions must apply: The premium is drawn from an account in the UK, Channel Islands or Isle of Man in the sole or joint name of the applicant The application is for a Term Assurance, Critical Illness or Income Protection The payment is by direct debit or personal cheque The premium does not exceed 100pm/ 1200 per annum 8 Third Party Premium Payer UK and GUERNSEY Completion of a VISF is required for the third party payer. Section C of the applicant s VISF should be completed to confirm third party details. Completion of a VISF/Introducer Certificate is required for all premium payer/s. ISLE OF MAN A letter from the applicant(s) stating the following: Relationship to the third party Reason for paying the premium Proof of address and identity for the premium payer SOW information from the premium payer, including occupation and salary details. If over premium limits, evidence required. Will be considered in exceptional circumstances. See comments Will be considered in exceptional circumstances. See comments FPI would always expect the applicant to pay the premium. In exceptional circumstances, FPI may consider a third party payment, provided we are satisfied with the reason for the request. Verification of identity for the premium payer is required - see the guidance opposite. Where an employer / company is the premium payer, please refer to Section 9 below. 9 Corporate/n- Individual verification of identity UK and GUERNSEY - Company as applicant/premium payer Private Limited Companies registered in the EU, Channel Islands, Isle of Man, Iceland and Gibraltar Completion of a VISF form for non-individuals or UK Introducer Certificate* for n-personal entities Certified authorised signatory list (required only where company is to be the policy owner) * For Guernsey contracts verification is required for shareholders who hold 5% interest or more Page 4

5 Private Limited Companies registered outside of the EU/Channel Islands, Isle of Man, Iceland and Gibraltar. The above plus: Completion of a VISF form for individuals for each of the following: - Shareholders with 25% interest or more* - Any ultimate beneficial owners - At least two directors * For Guernsey contracts verification is required for shareholders who hold 5% interest or more For other company and legal entity requirements, see the n-individual guidance grid or contact us on ISLE OF MAN - Company as applicant Certified copy of the Certificate of Incorporation A set of the latest annual report and accounts Certified authorised signatory list A letter from the applicant(s) confirming: A list of shareholders and certified ID and address verification for those holding more than 20% of the shares A list of all Directors and certified identification documents for two, one of which must be an executive (this includes obtaining verification of address) Confirmation that the company has not been, or is not in the process of being dissolved, struck off, wound up or terminated. ISLE OF MAN Company as premium payer Where the employer is the premium payer, the following is required: Letter from the employer confirming they are paying as part of employment package, e.g. pension contribution Certified copy of the Certificate of Incorporation Page 5

6 This document should be read in conjunction with the current brochure for the appropriate product, which, together with the policy document, sets out the terms and conditions of the contract. A copy of the policy document may be obtained from Friends Provident International Limited on request. Holders of policies issued by the Company will not be protected by the Financial Services Compensation Scheme if the Company should become unable to meet its liabilities to them. Policyholders will receive the protection of the Life Assurance (Compensation of Policyholders) Regulations 1991 of the Isle of Man. Copyright 2007 Friends Provident International Limited. All rights reserved. Friends Provident International is the trading name of Friends Provident Life and Pensions Limited and Friends Provident Life Assurance Limited for business conducted outside the United Kingdom. Registered & Head Office: Pixham End, Dorking, Surrey RH4 1QA England Incorporated companies limited by shares and registered in England. Friends Provident Life and Pensions Limited. Registered number Friends Provident Life Assurance Limited. Registered number Members of the Friends Provident Marketing Group and authorised and regulated in the United Kingdom by the Financial Services Authority. Salisbury Office: United Kingdom House, Castle Street, Salisbury, Wiltshire, SP1 3SH, England Telephone: +44 (0) Facsimile: +44 (0) Guernsey Office: Albert House, South Esplanade, St Peter Port, Guernsey GY1 1AW, Channel Islands Telephone: +44 (0) Facsimile: +44 (0) Friends Provident International is the trading name of Friends Provident International Limited. Authorised by the Isle of Man Insurance and Pensions Authority and regulated by the Financial Services Authority for the conduct of investment business in the UK. Provider of life assurance and investment products Registered & Head Office: Royal Court, Castletown, Isle of Man, British Isles, IM9 1RA Telephone: +44 (0) Facsimile: +44 (0) Incorporated company limited by shares. Registered in the Isle of Man All are members of the Association of International Life Offices. XIM/CHECKLIST 1.07