Financial Crime World

Chapter FC-1: Customer Due Diligence Requirements

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Face-to-Face Business

When conducting face-to-face customer due diligence, an authorized official must obtain original identification documents. If a document is copied or obtained electronically, it must be certified with the words “original sighted” along with the date and signature of the authorized official.

Requirements for Obtaining Original Identification Documents

  • Obtain original identification documents from customers.
  • Verify the authenticity of the documents.

Certification by Third Parties

If a customer is not present to provide their own documentation, the Islamic bank can use certification from a third-party official. This includes:

  • Lawyer
  • Notary
  • Chartered/Certified Accountant
  • Government Ministry Official
  • Embassy or Consulate Official
  • Licensed Financial Institution Official

Requirements for Third-Party Certification

  • The individual certifying the document must provide clear contact details.
  • The Islamic bank must verify the identity of the person providing certification through:
    • Professional organization membership (for lawyers and accountants)
    • Database checks
    • Direct phone or email contact

When dealing with legal entities or arrangements, such as trusts, the Islamic bank must obtain and record specific information from original identification documents, databases, or websites. This includes:

  • Entity name and trading names used
  • Registration number (or equivalent)
  • Legal form and proof of existence
  • Registered address and trading address (if applicable)
  • Type of business activity
  • Date and place of incorporation or establishment
  • Telephone, fax number, and email address
  • Regulatory body or listing body (for regulated activities)

The documents obtained under the above requirements must be certified in the same manner as specified for individual customers.

Note: This summary is based on a specific regulation from Bahrain and may not apply to other jurisdictions.