Q&As

Can a current, valid UK photo card driving licence alone satisfy client due diligence requirements?

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Published on LexisPSL on 05/04/2018

The following Practice Compliance Q&A provides comprehensive and up to date legal information covering:

  • Can a current, valid UK photo card driving licence alone satisfy client due diligence requirements?

Can a current, valid UK photo card driving licence alone satisfy client due diligence requirements?

STOP PRESS: Draft Legal Sector Affinity Group (LSAG) AML guidance was published on 20 January 2021. It awaits approval by HM Treasury and any content may be amended before the final version is published with the Treasury's approval. This document reflects HM Treasury approved LSAG AML guidance published in 2018 and will be updated in due course.

Practice Note: Money Laundering Regulations 2017—client due diligence—law firms explains that client due diligence (CDD) involves identifying the client and verifying their identity on the basis of documents or information obtained from a reliable source which is independent of the client.

Identification and verification are not the same:

  1. identification is simply being told or coming to know the client's identifying details, ie their name and address

  2. verification is obtaining evidence that supports this identification—the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 make it clear that you must verify on the basis of documents or information obtained from a reliable source which is independent of the person whose identity is being verified. Adopting a risk-based approach, AML Guidance for the Legal Sector suggests you may consider confirming these sources as valid by checking with the issuing authority. If the issuing

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