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Proceeds of Crime Act 2002 and Money Laundering Regulations 2007
Client Identity
We are legally required to check the identity of our clients and to keep records of that identity. We, therefore, ask for your co-operation in providing us, as soon as you instruct us, with basic identification documents. In an ordinary case this means that you should bring with you to your first meeting your original passport or photo drivers licence or other photographic identity and at least one utility bill or other official pieces of correspondence addressed to you at your home address (we recognise that in a few cases this causes difficulty and alternative arrangements can be made where this happens). We may be required, by law, not to inform you or anyone else that a report has been made and may not be able to proceed with the transaction or matter until we receive permission from the National Crime Agency (“NCA”) to proceed. As many of our clients are legal entities rather than individuals, we are also required to establish the ownership of, for example, a company or a partnership. This may require us to seek further identification information.
Funds
It is your responsibility to satisfy us as to your identity and your entitlement to any funds arising from transactions which we deal with and to satisfy us as to the origin of any funds to be received by us or dealt with by us in transactions for which we are retained.
Reporting
We, together with any other professional advisers, are legally obliged to make a report to the NCA if we are suspicious that any matter or transaction involves the proceeds of crime. Where so required by law we are not usually able to inform you or anyone else that that report has been made. Nor, in such circumstances, is any party allowed to proceed with the transaction or matter concerned until we receive permission from NCA to proceed.