Question from a firm – When a client moves address, do you need to redo the Money Laundering (ML) verification checks?
Answer – You should obviously update your records and then consider, on a risk sensitive basis, what (if any) evidence you need to support the change (e.g. obtain copy of a utility bill for the new home address – preferably a physical utility like gas/electric/broadband, but not a mobile phone bill). For most clients I would have thought that routine correspondence and dealings with the client would provide sufficient evidence to corroborate the change.
Also bear in mind the need to verify that the related appropriate update has been made to the RBO register entries (which are actually the client’s responsibility). This applies where the client is a beneficial owner of either a limited company or an Industrial & Provident Society. Such updates must be made ‘in a timely manner’ according to SI 110/2019.
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