Handbook of Anti-Money Laundering.

CHAPTER 15RETAIL CUSTOMER IDENTIFICATION

15.1 WHO ARE RETAIL CUSTOMERS?

Retail customers are essentially private individuals who act in their own capacity. Customer identification procedures that are suitable for personal customers will inevitably be different from those that are applied to corporate customers. This is due to the nature of the relationship and also the nature of the documentation that is available to retail customers to provide to the financial institution.

Of course, in corporate relationships it may still be appropriate to identify some of the owners, controllers or stakeholders depending on the nature of the relationship. In such cases, the process that is undertaken is similar to that addressed in this chapter and will be in addition to the procedures to be adopted in respect of corporate customers, which are discussed in Chapter 16.

The procedures that will be adopted within a firm will need to meet the requirements of both their host (i.e. the jurisdiction where they are based) and home regulatory regime (i.e. the jurisdiction where their head office is based). The host requirement is obvious: since the firm is conducting business in that country it will need to comply with the rules of that country. In this chapter we discuss general requirements and provide UK-based rules as an example. In the country profiles included within Chapter 27, you will find summary specific requirements for specific countries.

We have also suggested that it would be wise ...