If a client does not have an acceptable form of photo identification, you should first refer to your agency's AML policy or speak to your Money Laundering Officer (MLO) to determine what alternative forms of identification can be accepted. In most cases, where a client does not have an acceptable form of photo identification, two of the below will be required.
- Original birth certificate.
- Adoption certificate.
- Marriage or civil partnership certificate.
- Decree Absolute or Deed Poll.
- HM Forces identity card.
- Benefit entitlement letter.
- HMRC correspondence confirming a National Insurance number.
- Old-style UK paper driving licence
If your client does not have any of the standard identity documents listed above, you should speak with your MLO to determine the most appropriate course of action.
Depending on the client's risk level, the circumstances, and your agency's AML policy, it may be appropriate to accept an alternative form of identification alongside additional due diligence.
Examples of non-standard documents that may be considered include:
- Concessionary Bus Pass.
- Letter from a care home or residential care provider.
- Letter or statement from the client's family solicitor.