Anti-Money Laundering requirements of Stockbroker.

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Tintagel

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My stockbroker Campbell O Connor, is asking me to provide certified copies of my Passport or Driving Licence, a certified copy of my bank statement and a certified copy of my utility bill in order to update my Anti-Money Laundering identification.

I have no problem in providing my passport and utility but I am wondering why they need to see a copy of my bank statement. Is this a normal requirement?

The transactions on my bank account statement are private to me. It is also a joint account so should I really be asked to provide details of my partner's transactions as well?

Any opinions?
 
Tintagel said:
My stockbroker Campbell O Connor, is asking me to provide certified copies of my Passport or Driving Licence, a certified copy of my bank statement and a certified copy of my utility bill in order to update my Anti-Money Laundering identification.

I have no problem in providing my passport and utility but I am wondering why they need to see a copy of my bank statement. Is this a normal requirement?

The transactions on my bank account statement are private to me. It is also a joint account so should I really be asked to provide details of my partner's transactions as well?

Any opinions?
Click to expand...

As it's just for address verification feel free to redact the transactions. They should have no issues with that. Similarly, they should allow you to provide a second utility bill in lieu of the bank statement once it's dated within their required timeframe (usually within 3 or 6 months). It's probably worth pointing out that they actually have no real interest in reading the statement but are just requesting it as it's the handiest for meeting their customer due diligence obligations.
 
I am just updating my paperwork for them. I have had an account with them for 15 or so years. They already have similar information on file. In the past I was never asked for my bank statement, just this time. My COC account is in my sole name, my bank account in joint names.

They are also looking for certified copies of the above. As I already have an account with them and older utility bills etc on file you would wonder why they need certified copies as I am only updating my existing information.

24601. Strange that they specifically asked for a copy of my bank statement. I don't think that this is a requirement under the Act?
 
Tintagel said:
I am just updating my paperwork for them. I have had an account with them for 15 or so years. They already have similar information on file. In the past I was never asked for my bank statement, just this time. My COC account is in my sole name, my bank account in joint names.

They are also looking for certified copies of the above. As I already have an account with them and older utility bills etc on file you would wonder why they need certified copies as I am only updating my existing information.

24601. Strange that they specifically asked for a copy of my bank statement. I don't think that this is a requirement under the Act?
Click to expand...

Yes, but most organisations subject to AML/CTF requirements have 'trigger' events where they have to update the information had on file about a customer. Part of the customer due diligence process involves keeping a customer's ID and address verification up to date so if they only have older docs on file for you they may need to update them.

The simplest thing would be just to ask them why they requested a bank statement and they should happily answer your query. I suspect that it's just one of the primary documents they have identified for updating customer information in line with AML requirements. The Act leaves a lot of latitude to individual organisations to determine what documents they deem acceptable which is a bit unfortunate as there is no standardisation across institutions as a result.
 
There is no requirement under the legislation to have to provide a bank statement. Two utility bills should suffice. I'd be careful about redacting transactions. I submitted a letter from a bank with the clients name, address and bank details on it but it was rejected because it had no transactions on it.


Steven
http://www.bluewaterfp.ie (www.bluewaterfp.ie)
 
Whilst it is correct to state there is no requirement to provide a bank statement as proof of ID, there are requirements under ongoing monitoring provisions to confirm "source of funds" and "source of wealth". The following is from the guidelines to the relevant act


A designated person shall monitor dealings with a customer with whom the
person has a business relationship, including (to the extent reasonably warranted
by the risk of money laundering or terrorist financing) by scrutinising
transactions and the source of wealth or of funds for those transactions, to
determine whether or not the transactions are consistent with the person’s
knowledge of the customer and the customer’s business and pattern of
transactions, and any knowledge that the person may have that the customer
may be involved in money laundering or terrorist financing.

Section 35(3) of the Act refers to “source of funds”. When scrutinising the
source of funds a designated person should seek to discover the origin and the
means of transfer for funds that are involved in the transaction (for example,
occupation, business activities, proceeds of sale, corporate dividends)


Section 35(3) of the Act refers to “source of wealth”. When scrutinising the
source of wealth a designated person should seek to discover the activities that
have generated the total net worth of the customer

It's possible this is why they are asking to see bank statements although to be honest, I've never heard of a broker requesting it before.
 
I've never come across the need to see proof of source of funds. Usually it is a tick the box. If you have reasons to be suspicious, you can ask for further proof. But the OP has been a client of theirs for 15 years. Why would they be suspicious now?

It is more likely because the AML legislation gives companies a lot of leeway in the documentation they require e.g. some companies allow statements within the last 6 months, others within the last 3 months. Maybe their compliance dept has come up with a rule that a bank statement and utility bill is what they want.


Steven
http://www.bluewaterfp.ie (www.bluewaterfp.ie)
 
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