Know Your Customer

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It is the policy of (ENTER YOUR ORGANIZATION’S NAME HERE) to comply with the (ENTER REGULATORY BODY HERE) Know Your Customer Requirements.  

Establishing identity:

The following information should be established and independently validated for all private individuals whose identity needs to be verified:      

1. the true full name(s) used; and
2. the permanent home address, including postcode where available.

The information obtained should provide satisfaction that a person of that name exists at the address given and that the applicant is that person. Where an applicant has recently moved house, the previous address should be validated.

Date of birth is required by the law enforcement agencies and it is therefore important for this to be obtained. However, the information need not be verified. It is also important for the residence/nationality of a customer to be ascertained to assist risk assessment procedures.

A risk-based approach should be adopted when obtaining satisfactory evidence of identity. The extent and number of checks can vary depending on the perceived riskiness of the service or business sought and whether the application is made in person or through a remote medium, such as telephone, post or the Internet. The source of funds, i.e. how the payment was made, from where and by whom, must always be recorded to provide an audit trail. However, for higher risk products, accounts or customers, additional steps should be taken to ascertain the source of wealth/funds.

For lower risk accounts or simple investment products, e.g. deposit or savings accounts without cheque books or automated money transmission facilities, there will still be an overriding requirement for the bank to satisfy itself as to the identity and address of the customer.

Documentary Evidence

• Personal Identity Documents:
  • Current International Passport
  • Residence Permit issued by the Immigration Authorities
  • Birth Certificate/Sworn Declaration of Age
  • Documentary Evidence of Address:
    • Record of home visit 
    • Confirmation from the electoral registers that a person of that name lives at that address.
    • Recent utility bill (e.g. NEPA, NITEL)
    • State/Local Government Rates
    • Bank statement or passbook containing current address.
       

Establishing Identity for Students and Minors

When opening accounts for students or other young people, the normal identification procedures set out in this manual should be followed as far as possible. Where such procedures would not be relevant, or do not provide satisfactory identification evidence, verification could be obtained:

• Via the home address of the parent(s);or
• By obtaining confirmation of the applicant’s address from his/her institution of learning.
• By seeking evidence of a tenancy agreement or student accommodation contract.

Often, a family member or guardian will open an account for a minor. In cases where the adult opening the account does not already have an account with the financial institution, the identification evidence for that adult, or of any other person who will operate the account, should be obtained in addition to obtaining the birth certificate or passport of the child. It should be noted that this type of account could be open to abuse and therefore strict monitoring should then be undertaken.

For accounts opened through a school related scheme, the school should be asked to provide the date of birth and permanent address of the pupil and to complete the standard account opening documentation on behalf of the pupil.