"Trust, but verify." - Ronald Reagan
This quote, while emphasising the importance of verification, also conveys a sense of respect and goodwill towards the client. It suggests that due diligence is not about suspicion or distrust, but rather about ensuring a safe and transparent relationship for both parties.
Prospective Clients and Existing Clients are subject to Client Due Diligence
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Why
We conduct due diligence on all prospective clients before engagement to comply with financial crime, counter-terrorism, and sanctions legislation and regulations.
What is Client Due Diligence
In line with industry regulations, we ask you some standard questions to verify your identity and understand your needs. This is a routine process similar to what you might experience in other professional settings.
An Illustration of the Process
Complete the Website Contact Form
We will then send you information on the compliance checks we undertake:
We will send you:
- a link to undertake the biometric check - via secure app - this is a bit like a selfie and takes minutes
- a link to the source of funds check - via secure app - the app will seek your consent and will take minutes
You complete all the requested checks
You will be prompted to answer some basic questions, and provided with information.
Biometric E-verifications: Bio-metric Check is a bit like a selfie or when you complete an online passport renewal. If you have any difficulties you can contact the tech provider. This takes a few minutes.
Source of Funds Checks: The source of funds check is an industry standard check. The secure app will guide you through prompts, as to the source of your funding to pay for your appointment or other work. This takes a few minutes.
NB: This industry standard secure check was originally designed to assist conveyancing firms to ascertain the source of funds for a purchase, its use has expanded, many firms use source of funds checks for all their clients (conveyancing and non-conveyancing clients alike). So when the prompt asks you how will you fund your purchase - take this to mean how will you fund your matter.
NB: The pre-set requests statement for the last 12months.
If you have any difficulties with the biometric check or the source of funds check you are able to contact the tech provider for support - details will be sent to you.
Online Questionnaire or In-person Questionnaire
We are required to ascertain information about you and your nature of your matter, and standard compliance questions.
The questionnaire online but it can be printed and used within the first few minutes of your appointment.
Examples of the types of inquires:
- Requests for your full details, background, whether your employed or self-employed, or have a business
- Details of the other party, nature of your issue
- Compliance Questions: e.g. are you connected with certain countries, whether you are a politically exposed person, etc
The questionnaire can be completed in about 10-15mins, and not all questions may be applicable to you.
Clarification
We may request clarification.
Book your appointment
We will send you a payment request so that you can pay for your booking in advance - via a secure payment app.
Then Schedule your Appointment for a date and time mutually convenient.
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Attend your appointment
We may ask you to bring some original documents with you such as:
- your unexpired passport
- your photo driving licence with your current address printed on it
- or other document (such as a utility bill with your full name and address on it - dated within the last 3months)
The above is only a general illustration, your actual pre-onboarding process may be different.
If your matter has a counterparty, a third party, if you have connections to high risk countries, or you or others are Politically Exposed Persons, or you have a business or other entity we will ask further questions and require documentation.
Identifying and verifying an individual persons is likely to be straightforward. Identifying and verifying entities such as companies and trusts can be more involved.
Individual Persons: Identification and verification
We are required identify and verify who the prospective client is.
| Individual Natural Persons | Preferred Forms of Personal Identification |
| E-Verification | Biometric Electronic Verification via secure app |
| Original | Unexpired Passport |
| Original | Current Address Photo Driving Licence |
| Original or Certified Copy | Utility Bill - stating your full name, your current address and dated within 3 months |
Entities: Identification and verification
Where a prospective client is an entity or a prospective client has an entity (company, partnership, trust or charity or other non-personal organisation) we have to identify the entities and verify them.
| Entity | Information and Documentation requested |
| Company | The Full Names of Directors and Senior Management The names of all the Directors and other persons who have and exercise strategic decision-taking powers or who have and exercise executive control; Identification of each Director E-verification biometric check and - a certified copy passports (ALL PAGES) - a certified copy of a current utility bills or a bank statement that is not less than 3 months old Certification: signed and dated by a suitable certifier whom have had sight of the original(s) and certifies the copies to be true copies of the original document(s) and all photographic evidence to be a true likeness of the holder(s) Shareholders We require details of any shareholder holding 25% of the shares or more. Voting Rights Address of Registered Office Proof of the address of the registered office (if different from your trading/mailing address) Proof of your principal place of business/operations (if different from the above) Certificate of Incorporation Proof of the company name and any trading names Proof of the official identification number Certified copy of the certificate of incorporation which must be signed and dated by a suitable certifier whom have had sight of the original(s) and certified the copies to be true copies of the original documents Memorandum and Articles of Association Certified copy of the Memorandum and Articles of Association which must be signed and dated by a suitable certifier whom have had sight of the originals and certified the copies to be true copies of the original documents |
| Partnership | The Full Names of all Partners The names of all the Partners Partners Proof of Identity E-verification biometric check and- a certified copy passports (ALL PAGES) - a certified copy of a current utility bills or a bank statement that is not less than 3 months old Certification: signed and dated by a suitable certifier whom have had sight of the original(s) and certifies the copies to be true copies of the original document(s) and all photographic evidence to be a true likeness of the holders Partnership Agreement Certified copy of the Partnership Agreement which must be signed and dated by a suitable certifier whom have had sight of the originals and certified the copies to be true copies of the original documents Registration Proof of the name of the partnership and any trading name Proof of the date and country of incorporation/registration and official identification number Address of Registered Office Proof of address of the registered business/office; Proof of the postal address (if different from the above) Proof of your principal place of business/operations (if different from above); |
| Trust and Estate Administration | to be updated |
| Charities | to be updated |
| Clubs and Associations | to be updated |
| Other entities | to be updated |
Source of Funds and Source of Wealth:
Funding your initial fixed fee appointment and further work?
Why are you asked questions about your funding source?
You are asked questions because as the firm is a part of a regulated industry, we are required to ascertain the source of the funds that we accept as payment. We are not able to accept funds that sourced from illicit acts or move funds that have been received from a sanctions individual. Whilst you know you are not involved in anything illicit and that you know you are not a sanctioned designated person, we are require to have a process and to make checks.
We provide below examples of the types of information and documentation generally requested. They are likely to be details that you will have available to you.
How are you funding your matter? What is the Source? Source of Funds and Source of Wealth | Information and Documentation that might be requested |
| Employment Income: Do you intend to fund your matter from your monthly income? |
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| Savings: Do you intend to fund your matter from your savings? | Bank statements, that will show where the funds came from |
| Property: If you intend funding your matter from the proceeds of sale? |
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| Shares or other investment: Do you intending to sell your investments or have you already sold them and intend to use this source of funds/wealth to fund your matter? |
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| Loan: Have you obtained a loan |
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| Company Sale: |
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| Company Profits/ dividends: |
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| Inheritance: |
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| Gift: |
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| Maturity/ surrender of policy: |
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| Other income sources: |
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Certification
Where documentation is requested, you can provide the original documents or you may find it more convenient to provide us with certified copies.
The following are a non-exhaustive list of professionals or organisations that can certify your documentation:
- A member of the Judiciary, a Senior Civil Servant, or a Serving Police or Customs Officer
- A Practicing Solicitor or Barrister
- An officer of an Embassy, Consulate or High Commission of the country that issued the documentary evidence of identity
- A notary
- A Tax Adviser
- An Accountant
- An Insolvency Practitioner
- An auditor
- A credit or financial institution which is an authorised person
- A consumer credit financial institution
Costs of Certification
The costs associated with certification are your expense and are not recoverable from us under any circumstances. So, if we decide not to take on you as a client you will not be able to recover this expense from us.
Certifier
The certifier must certify that the copy is a true copy of the original document and a true likeness in the case of a photograph.
In addition, the certifier must include an adequate level of information which needs to include their name, position or capacity, their address and telephone number or email address at which they can be contacted, and their official seal.
Please note a person cannot be a suitable certifier if they are:
- related to the person being identified by birth or marriage; or
- in a relationship or living with the person being identified.
Ongoing Monitoring:
- Client due diligence is not an inception event only.
- We are required to update your client due diligence (CDD) throughout the life cycle of the matter and the business relationship.
- Therefore we will ask you to provide updating information from time to time. You should also inform us if you have a change in circumstances.
- If you fail to comply with these requests, we will not be able to proceed with your matter, and the retainer will be terminated. This is generally and industry standard.
Please note:
- We have stated a basic illustration of the process, it can be more involved depending on the prospective clients individual circumstances, counter-party, and third parties. There may be an an entity, which will lead to consideration of the entity's structure, ownership, control and influence and the disclosure of certified documents from independent reliance sources.
- The electronic verification checks, usually include behind the scenes checks such as: Sanctions check to ascertain if a prospective client is a designated person under the UK Sanctions Regime, US Sanctions Regime or UN Sanctions Regime, they will also be Politically Exposed Persons (PEP) check, Adverse Media check, and a light Credit check, as well as other checks such as a Mortality check, Electoral Roll check, and etc. These check are to establish you identity, and that you are not a designated person. This is ultimately to prevent our firm from being involved with a breach of the law.
- A prospective client is not a client of the firm until you have been through the pre-onboarding process, we feel comfortable about their responses, and we have agreed to take on the prospective client and matter and you have signed terms and conditions of business, and complied with any additional requests made at that stage.
- There is no obligation for this firm to take on a prospective client or matter, generally.
- Given our firm's size and operational scope, we may be unable to accept certain prospective clients or matters. This decision, for which we are not required to provide specific reasons, may be based on factors such as: potential sanctions risks involving the prospective clients, counter-party, or third parties; complex structures exceeding our expertise; or circumstances falling outside our risk appetite. In some cases, matters requiring a dedicated compliance team for assessment may also be declined. We appreciate your understanding.
- We do charge a separate fee to the initial consultation fixed fee for use undertake the compliance checks. This is generally referred to as an administrative fee. Please see the relevant fees page.
- Please note that if you provide information about counter-parties, third parties, that you should provide them with our privacy and that you obtain their consent. Will thus presume that you have undertaken the aforementioned.
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Contact Us
See our Privacy Page
See our Client Due Diligence Page
See our Pre-onboarding Page
Call Us: 020 4578 4684
Get in Touch at Any Time
Do not hesitate to contact us with any queries.
Alexander Christian
Harrow Business Centre
429-433 Pinner Road
North Harrow
Middlesex
Greater London
HA1 4HN
Phone : 020 4578 4684
www.alexanderchristian.co.uk