AML Requirements for Trusts with Individual Trustees
嚜澹or 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 每
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:
每 Financial Advisers
每 Regulated Financial or Credit Institution including Intermediaries
每 Commissioners for Oaths
每 Justice of the Peace
每 Notaries Public/Practising Solicitors
每 Practising Chartered & Certified Public Accountants
每 Embassy/Consular Staff
每 Police Officers
每 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;
每 Full Name
每 Full Residential Address
每 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 每 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:
每 a certified copy of a bus pass which includes
name, photo and signature of the client; OR
每 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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