Hi Amy,
You should tell your client when you ask for their photo identification and a confirmation of their home address that you require them to comply with your duties under the Money Laundering Regulations. You don't need to say any more than that.
As you take on more clients it just becomes a matter of routine to ask for it and people these days are used to being asked to produce identification documents when opening accounts at various places.
Once you have the documents on file as long as you comply with the principles set out by the Data Protection Acts you should not have any problems - either from a data protection or an AML perspective.
Chris
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