New Anti-Money Laundering Requirements for Lawyers from 1 July 2018
From 1 July 2018, all law firms must comply with the requirements of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (“Act”).
The Act obliges law firms to carry out “customer due diligence” (“CDD”) on new and existing clients where the nature of the work to be undertaken is captured by the Act. In broad terms, the Act captures the following work:
Managing client funds
Buying, selling or leasing any interest in land
Buying or selling a business or shares
Forming a company, limited partnership, trust or other legal arrangement
To complete CDD, we will need to collect information about your identity (including full name, date of birth and address) and in some cases the source of funds and/or wealth. For a company or trust, we will need this information for persons with effective control (which may include directors and executives), and beneficial owners holding more that 25%. To complete CDD, we will need to obtain copies of your identification and proof of address documents. If we cannot sight the original, we will need you to provide a copy verified by a trusted referee.
If we are required to complete CDD on you, we will be in touch where the information we already hold is not sufficient to meet the Act’s requirements.
The relevant forms can be found here: