- Also in this section:
Before we act on your behalf, to ensure compliance with the Anti Money Laundering Regulations (AML), we will require to obtain proof of your identity and home address. This may be done by: you providing us with documentation (as set out below at A. and B); by an electronic AML check, (for which a charge is levied – see page Fees section Charges – How do we charge for work? (d); a combination of the two.
By entering into a contract instructing us to act on your behalf you agree and acknowledge that the Firm may use an external agency to undertake an electronic AML check. This check will involve an individual identity check(s) and for Limited Companies and Limited Liability Partnerships a business check and individual checks on the directors / partners / persons with significant interest.
The Legal Sector Affinity Group identifies certain legal matters as posing a higher risk for the potential for money laundering corruption. These include, but not limited to: property conveyancing; setting up a new business or trust; administration of a deceased person’s estate. For all matters that pose a potential for high risk, we will undertake an electronic AML check. For all other non-higher risk matters, you may expressly ask the Firm not to carry-out an electronic AML check. However, without the permission of our Money Laundering Regulation Officer (MLRO), or deputy MLRO, we may not be able to act. If we do proceed, you agree to provide the following documents, one each from list (A) and list (B):-
A. A current valid full passport, OR a current driving licence OR a photographic National Identity Card.
B. A Council Tax Bill, (must be for the current financial year), OR one of the following original documents dated within the last three months: An Electricity Bill; OR Gas Bill; OR Telephone Bill; OR Bank Statement. MUST DISPLAY CURRENT HOME ADDRESS.
These original documents will need to be provided to us, preferably by hand, or by Special Delivery post. Alternatively, if it is not practical please arrange for ‘certified as true copies of the originals’ to be forwarded to us. [This can be done by a solicitor in your vicinity, or by a financial institution].
If we do not receive this information we may not be able to progress your instructions.
All personal data held by us will be processed only for the purposes of the regulations / law current from time to time pertaining to either, or both, ‘Anti-Money Laundering’ and ‘Counter Terrorist Finance’. The data will be kept for: (i) a minimum of five years after the end of our business relationship with you, (ii) such longer period as is required by the legislation, (iii) such longer period as we consider appropriate for operational purposes and in compliance of Law Society of Scotland requirements.