The identity checks the Money Laundering Regulations 2017 demand of solicitors — what triggers them, how deep they must go, and what follows when they cannot be completed.
Knowing who a client really is, and where their money comes from, sits at the heart of anti-money laundering compliance. This chapter begins with when the duty to carry out customer due diligence arises, then works through standard CDD on individuals and companies, including the rules for identifying beneficial owners. It moves up to enhanced due diligence for higher-risk situations such as politically exposed persons, and down to the simplified regime available where risk is low. It closes with ongoing monitoring, record-keeping and the consequences of incomplete CDD, before covering reliance on another firm's checks and the firm-wide compliance and training obligations that underpin the whole regime.