# Anti Money Laundering and Change of Address



## Bedlam (16 Sep 2016)

Hi 

I was surprised to be asked for a Utility Bill and Photo evidence by an Life Insurance Company when I was advising them of my change of address, why would they require this for a simple change of address? 

Bedlam


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## Steven Barrett (16 Sep 2016)

Your title is the answer, anti-money laundering rules. They are extremely strict and became even stricter at the start of the year. 

It's a nightmare to deal with as the legislation leaves it open to each company to set their own AML rules, so some companies require 2 forms of address verification, others 1. Some companies need the document to be dated within the last 3 months, others 6 months. 

There is no point in fighting against it, compliance depts make the rules these days. They won't change the address without you providing AML documentation. 


Steven 
www.bluewaterfp.ie


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## Gerry Canning (16 Sep 2016)

Most of this money laundering (rule) is a waste of time and resources, and has now taken on a life of its own.
I expect the (real) money launderers to have the easy ability to concoct false docs and I expect Life Company /bank etc to accept  Id  that (looks) ok ,in good faith.
Its a bit like the false security around flying .!

Maybe more people should voice their annoyance ?


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## Bedlam (16 Sep 2016)

Hi Steven

"compliance depts make the rules these days." But shouldn't compliance requirements be as per the AML legislation? I can find no reference to a change of address  being subject to AML requirements 

Bedlam


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## Gerry Canning (16 Sep 2016)

Bedlam,

I assume you are correct and if so it highlights the (box) filling ,self covering of this !


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## Jim2007 (16 Sep 2016)

Gerry Canning said:


> Most of this money laundering (rule) is a waste of time and resources, and has now taken on a life of its own.
> I expect the (real) money launderers to have the easy ability to concoct false docs and I expect Life Company /bank etc to accept  Id  that (looks) ok ,in good faith.
> Its a bit like the false security around flying .!



Well speaking as someone who has worked on the other side I can say that it most definitely works.


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## T McGibney (16 Sep 2016)

Bedlam said:


> Hi Steven
> 
> "compliance depts make the rules these days." But shouldn't compliance requirements be as per the AML legislation? I can find no reference to a change of address  being subject to AML requirements
> 
> Bedlam



How on earth can organisations vouch for customer addresses, as AML legislation requires, if they lack processes to track and record changes in such addresses?


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## Bedlam (16 Sep 2016)

Hi Tommy,

Fair point,  but why I would I bother notifying a company of a change of address if I hadn't changed address?


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## T McGibney (16 Sep 2016)

Bedlam said:


> Hi Tommy,
> 
> Fair point,  but why I would I bother notifying a company of a change of address if I hadn't changed address?


If you wanted to subvert the legislation by setting a false trail for the Gardai?


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## Gerry Canning (16 Sep 2016)

Jim2007 said:


> Well speaking as someone who has worked on the other side I can say that it most definitely works.



I have no doubt that there are odd cases where (it) catches chancers.
From experience (and I do work on the other side) it is applied as a must do, (bum covering) rather than a real exercise.
Most of those (caught) trying to mess , are low -level twits!

The real (fraudsters) ,bigger boys , just read the rules and create proper looking docs,.


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## Bedlam (16 Sep 2016)

"If you wanted to subvert the legislation by setting a false trail for the Gardai?"

The policy is for a mortgage which is assigned to the bank that did the life policy and provided the loan so it is their money for the next 29 years.........so no need for a false trail anywhere. The bank have an application for a mortgage which notes the loan is for the property that I now which to change my address to and now their life company want further proof............how many paper trails do they need?

I can find no reference in the legislation that states a change of address on an existing policy is subject to money laundering requirements.


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## Steven Barrett (19 Sep 2016)

It's under the Common Reporting Standard that came into effect on 1 January 2016. 



Steven 
www.bluewaterfp.ie


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## Bedlam (19 Sep 2016)

Hi Steven,

"It's under the Common Reporting Standard that came into effect on 1 January 2016" 

Below is from the FAQ section of the Revenue on this. 

8. Residence address test for Lower Value Accounts. A jurisdiction may allow Financial Institutions to determine an Account Holder’s residence based on the residence address provided by the account holder so long as the address is current and based on Documentary Evidence. The residence address test may apply to Preexisting Lower Value Accounts (less than $1 million) held by Individual Account Holders. This test is an alternative to the electronic indicia search for establishing residence and if the residence address test cannot be applied, because, for example, the only address on file is an “in-care-of” address, the Financial Institution must perform the electronic indicia search. The residence address test option is not available for FATCA. The EU Directive includes the residence address test. (Section III, subparagraph B(1); Commentary on Section III, subparagraph 7-13) 9. Optional Exclusion from Due Diligence for Preexisting Entity Accounts of less than

As the policy in question is for Life Cover only whereas the above appears to deal with Investment Accounts so surely should not be applied here?

Thanks

Bedlam


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## Steven Barrett (20 Sep 2016)

Bedlam

I have had enough battles with compliance departments over their rules and always lost, so now I just give them what they want. I read the AML legislation and is gives companies enough discretion to make their own rules with the amount of forms they want. I haven't read the CRS as the legislation is very boring. 

Steven 
www.bluewaterfp.ie


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## Gerry Canning (20 Sep 2016)

From the thread I reckon.

1. Most compliance is job creation for form fillers.
2. Compliance has subverted common -sense .
3. Once compliance is happy ! , you can then proceed to con away !
4. Sad that people like Steven (and indeed mise) just give up.


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## Setanta12 (20 Sep 2016)

Hmmm ... I take a dissenting view.  AML or to be more polite 'KYC' 'Know Your Client' is precisely for that reason, so there is no wiggle-room to avoid taxes.  FATCA was hated by the world when it was brought in - but everyone has signed up.  Even the Swiss are feeling the heat here as another poster recently pointed out.

The Panama Papers gave an insight into international tax planning and the use of Trusts.  Looking closer to home, we see charities mixed up with S110 companies.

Incidentally, there is a certain political party on the left with a huge property portfolio all in the legal-ownership of individuals, the beneficial ownership rests elsewhere .. .. ..


AML/KYC procedures are designed to bring the identity of beneficial owners to the fore - this is also of international concern and will be the subject of a OECD paper soon.


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## Steven Barrett (20 Sep 2016)

I have no problem with AML docs Setanta, I just wish there was a uniform standard across all financial institutions. Some require 2 address verifications, others 1. Some have to be within the last 3 months, others 6 months. The legislation states that documents that are issued once a year such as a P60, should be accepted but I have had them rejected as they were issued outside that companies allowed time period. 

Steven 
www.bluewaterfp.ie


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## johnny1234 (20 Sep 2016)

This is a very interesting topic. I know of an institution that has money invested for parties that was received via serious criminal activities, in another jurisdiction. We're talking serious wedge here and the hierarchy of the institution know it but turn a blind eye on it. What does one do, especially as I have very serious issues with the same institution.


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## Bedlam (21 Sep 2016)

Good Morning All,

Below is my original post and I have noted an agree with the need for AML/KYC but as mentioned in a later post this is for a Life Policy assisgned to a Bank!! and therefore it appears to me that this Compliance operating in a illogical manner

"I was surprised to be asked for a Utility Bill and Photo evidence by an Life Insurance Company when I was advising them of my change of address, why would they require this for a simple change of address?"

On a more serious note.................

Johnny1234 you should be reporting your concerns to the Gardai  

Thanks

Bedlam


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## Steven Barrett (21 Sep 2016)

Know your client has a different purpose to AML requirements. KYC is to show that the investment is suitable for the investor. AML is to prevent money laundering. 

Johnny1234, if you are in an occupation that is regulated, you have a legal obligation to inform the Gardaí. 

Steven 
www.bluewaterfp.ie


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## Bedlam (26 Sep 2016)

An update on this for people

The Insurance Company in question has conceded that they were incorrect in looking for AML for a change of address as the policy in question was a life policy.

Bedlam


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## Steven Barrett (26 Sep 2016)

Well done for sticking with it. Do you want to name the company so I can bash them over the head next time they ask?


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## Bedlam (27 Sep 2016)

Hi Steven

The company in question was New Ireland and they have agreed to amend their procedures / requirements for Life Policies when it involves changes of address.

Regards

Ken


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## Steven Barrett (28 Sep 2016)

Thought it was them. 

Thank you for doing us all a favour!


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