AML Requirements for Trusts with Individual Trustees

For Adviser use only

AML Requirements for Trusts

with Individual Trustees

> Please note PIA reserves the right to request additional

information and documentation as required

Documentation quality ¨C

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 identifying a natural person,

certify that it is a 'true likeness' of the individual, or words to that effect; and ensure

that the certifier's name is clearly shown in block capitals along with their signature;

> The certifier must also state a telephone number (or other means of contact), and a

statement as to their authority to certify (to include a professional registration where

applicable). If they are certified by the Financial Advisor (or other party) and their

contact details are already available on another document (or they are available

online); then the contact details do not have to be stated on the certified document.

> 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:

¨C Financial Advisers

¨C Regulated Financial or Credit Institution including Intermediaries

¨C Commissioners for Oaths

¨C Justice of the Peace

¨C Notaries Public/Practising Solicitors

¨C Practising Chartered & Certified Public Accountants

¨C Embassy/Consular Staff

¨C Police Officers

¨C Councillor (in the UK, Jersey, Guernsey and Isle of Man only)

Source of Wealth

A confirmation of the 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; and 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.

2 AML Requirements Guide

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.

All Settlors, Protectors and Controllers of a Trust

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 Settlors, Trustees, Beneficiaries and Authorised signers.

> Certified Copy of the Authorised Signatories List (required where signatories are

not identified in the trust deed or where the signatures have not been provided).

> CDD for the Settlor of a Trust.

> Customer Due Diligence (CDD) for all Trustees (As per Section 2 below).

> For Absolute Trusts we require all beneficial owners to be identified on the

Application form, or Declaration of Beneficial Ownership form. The

information required to identity is;

¨C Full Name

¨C Full Residential Address

¨C Date of Birth

> For Absolute Trusts we require CDD for all Beneficial Owners with an interest in

the Trust.

> For Discretionary Trusts we require a list of the classes of beneficiaries covered by

the Trust, if not already defined in the Trust Deed.

> CDD for Controller or Protector of the Trust.

> CDD of an authorised signatory that signs the application form and if different to any

of the individuals noted above to whom CDD may have already been applied to.

Helpful Hints:

We always need CDD for all beneficial owners of trusts ¨C this always has to be a natural person or

regulated entity.

AML Requirements Guide 3

2. Additional AML Requirements for Individuals (Trusts)

2.1 Standard Requirements

1 x Proof of Identity

1x Proof of Address:

Note: PO Box addresses not accepted. Proof of address needs to detail name

and address in full

> Current valid signed certified

> Utility Bill (up to a maximum of six months old including TV license bill for UK

copy of passport (expiry date

should be carefully checked)

>

Certified copy of Driver's

Licence with Photo issued in

the UK, EU, EEA Member State,

Channel Islands, or Isle of Man;

and which shows name and date

of birth

> Certified Copy of Valid State

ID with Photo issued by the EU,

or an EEA member state only;

and which shows name and date

of birth

residents only)*

> Local Authority Tax or Utility Bill (current year)

> Current Drivers Licence issued by UK, EU member state, Channel Island or Isle

of Man* (photo or non photo). Cannot be used as address ID if being used for

Personal ID

> Bank/Building Society/Credit Card statement, or a Credit Union statement or

passbook; containing address and no greater than six months old

> Mortgage statement from recognised lender (up to a maximum of 12 months old)

> Letter from Her Majesty's Revenue and Customs (HMRC) or Department

for Work and Pensions (up to a maximum of 12 months old)

> Solicitor¡¯s letter confirming house purchase; proof of previous address must be

supplied (only acceptable for clients in between property moves)

> State ID from an EU Country (Cannot be used as address ID if being used for

Personal ID)

> National Tax Bill for current year including Notice of Coding

> Insurance Statement/Certificate from a regulated institution in the EEA/EU

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

4 AML Requirements Guide

Important:

In all cases a written confirmation from the Intermediary with appropriate explanations as to why the

customer cannot provide the standard documents listed is required.

Non-Standard ID

Where an individual is genuinely not in a

position to provide the standard evidence of

identity and proof of address, it is important

that he/she are not prevented access to the

financial system solely due to not being able

to produce particular documentation.

The following is a non-exhaustive list of

alternative documents that can be used to

verify identity and address in circumstances

where a prospective customer cannot, for

justifiable reasons, meet standard

identification and verification requirements.

The documents below are not restricted to

the categories outlined but arranged in this

manner to assist identifying the types of

documents that might be available.

Proof of Identity

Reason

Acceptable Documents

Where an up to date

passport or driving licence

cannot be provided as the

document has expired

> a certified copy of the expired document;

AND

> ONE of the following:

¨C a certified copy of a bus pass which includes

name, photo and signature of the client; OR

¨C a certified copy of a birth certificate;

Where Proof of Identity

cannot be provided as

the standard document is

in a maiden name and the

application is in a married

name

> a certified copy of the passport or driving

licence which meets the requirements;

AND

> a certified copy of a marriage certificate which

clearly discloses the link between the maiden and

married name.

Note: This list is UK centric and some

of the items may not be acceptable

from other territories. This list of

non-standard documents applies to

New Business only.

AML Requirements Guide 5

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