As a will writer, you are required to take all reasonable and proper precautions to verify the identity of your client and that the instructions you take come from that person. This is in accordance with the Money Laundering Regulations 2007.
Before you proceed with taking the instructions form the client, you should obtain 2 form of ID from each of your clients. One must be photo ID and the other must be a proof of address.
You should obtain one document from list A and one document from list B
List A – Identity Document
- Current signed passport
- Valid UK photo driving licence
- EEA member state identity card
List B – Proof of Address
- Valid UK/EU/EEA Drivers Licence – if not used from List A
- Bank or building society statement
- Utility bill
- Council tax bill
- Mortgage statement
Any document produced for proof of address must be no older than 3 months and must have the client’s current address. A copy of the ID should then be kept with the file so you can show you took steps to identify the client before taking instructions.
With the current situation and remote instruction taking, we understand and appreciate it will not be easy to obtain a copy of the ID. Therefore, you could ask the client to send you a photo of their ID prior to the meeting. Before the meeting commences, ask to see the ID which the client can then hold up to the camera.