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Guidance Notes on Anti-Money Laundering (AML) Procedures

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Definition of Verification Subjects

The following individuals are treated as verification subjects:

• Partners in a firm applying for business who have individual authority to operate relevant accounts or give instructions.
• Limited partners need not be verified unless they are significant investors.
• Directors and shareholders of a company (including corporate trustees) are treated as verification subjects, except for:
  • Private companies with substantial premises and payroll.

Companies

Companies that do not require verification of underlying beneficial owners include:

• Those quoted on a recognized stock exchange
• Subsidiaries of such companies
• Private companies with substantial premises and payroll

Intermediaries

Institutions treating an intermediary’s account on behalf of an underlying customer may be exempt from verification, but if documentation is in the intermediary’s name or they have power to operate accounts, they should also be treated as verification subjects.

Monitoring for Undisclosed Principals

Institutions should monitor activities to identify potential undisclosed principals and verify them accordingly.

Exempt Cases

Verification is not required for:

• Small one-off transactions unless linked.
• Certain postal, telephonic, and electronic businesses may be exempt from verification if they do not provide payment facilities or transfer funds to other types of accounts.

Reporting Suspicious Transactions

If an institution suspects laundering or has occurred, the exemptions and concessions do not apply, and reporting is required.