For most businesses the basic information of just the name and address is usually enough especially when dealing with the normal type transactions. There are times we may need to gather more information on the client in line with the JMLSG definition of identity above. For example:
- Date of Birth – Required for items such as payroll.
- UTR – The Unique Tax Reference number from the Revenue (if issued)
- NI Number – The unique National Insurance Number, this is the secondary tax reference number and will be declared on P60.
- Place of Birth – Important in establishing residence and domiciliation/Marital status
- Family history – Important information
- Business Details – Are transactions in line with the business profile?
- Investments/savings – Any unearned income? Any rental income?
- HMRC registration or other government department. contact
- How did you hear about us? – Connections with existing clients
Your firm will have a system such as a ‘permanent file data sheet’ as part of the client files, it is normal working practice, this is where information such as the above is recorded and updated on a regular basis. Those of who strive towards a ‘paper less office’ will have a ‘practice management’ programme which will allow them to set up a set of ‘parameters and recording’ functions for each client. Whether on paper or electronically, this is part of the record keeping requirement for KYC as one of the firms’ requirements under the ML regulations.