Fact or fiction?
When the date on the passport used to verify a client has expired, I should always ask for an updated version or form of ID.
Fiction: ICAEW does not require you to obtain a new passport once a client’s document has expired. If the original ID was valid at the time of verification, your obligation has been met. The only circumstances where you should seek updated ID are if you believe the original may have been falsified, or if the client’s details have changed (for example, a change of name).
The regulations say that I must identify and verify all ultimate beneficial owners for a normal risk client
Fact: For all normal and high risk clients, you must identify and verify the ultimate beneficial owners (UBO). A UBO must always be a natural person, not an entity or a trust. You need to know who they are and confirm that they are who they say they are.
The regulations say that I must identify and verify all directors of a normal risk client.
Fiction: You should identify all directors, but verification is risk based. In most cases, you will only need to verify at least one, which will usually be your main point of contact. The number of directors you choose to verify should be determined by your risk assessment and documented in your procedures.
I must meet the client or beneficial owners face to face
Fiction: A face to face meeting is not required under the regulations. A risk based approach should be applied, remote meetings (for example, via Teams or Zoom) may be sufficient, provided the overall risk is low. What matters is that you obtain valid proof of identity and can demonstrate your client due diligence is robust.
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