IEIM404100 - Miscellaneous: Documentary Evidence: Document Sharing

Miscellaneous: Documentary Evidence: Document Sharing

Documentation is required to support the status of each financial account held. However in the following circumstances documentation obtained by a Financial Institution can be used in relation to more than one financial account.

Single Branch System

A Financial Institution may rely on documentation furnished by a customer where an existing customer opens a new financial account with the same Financial Institution and where both accounts are treated as a single account or obligation for due diligence and reporting purposes [see IEIM402500].

Universal account systems

A Financial Institution may rely on documentation furnished by a customer for an account held at another location of the same Financial Institution or at a location of a Related Entity of the Financial Institution if the Financial Institution treats all accounts that share documentation as a single account for due diligence and reporting purposes, and the Financial Institution and the other location or related entity are part of a universal account system that uses a customer identifier that can be used to retrieve systematically all other accounts of the customer.

In this scenario a Financial Institution must be able to produce to HMRC the necessary records and documentation relevant to the status claimed (or a notation of the documentary evidence reviewed, if the Financial Institution is not required to retain copies of the documentary evidence for AML purposes).

Shared account systems

A Financial Institution may rely on documentation provided by a customer for an account held at another location of the same Financial Institution, or at a location of a member of the Related Entity Group of the Financial Institution, if:

  • the Financial Institution treats all accounts that share documentation as consolidated accounts, and
  • the Financial Institution and the other location or Related Entity Group member share an information system, electronic or otherwise, that is described below.

A shared account system must allow the Financial Institution to easily access data about the nature of the documentation, the information contained in the documentation (including a copy of the documentation itself), and the validity status of the documentation.

If the Financial Institution becomes aware of any fact that may affect the reliability of the documentation, the information system must allow the Financial Institution to easily record this data in the system.

Additionally the Financial Institution must be able to show how and when it transmitted data regarding such facts into the information system and demonstrate that any data it has transmitted to the information system has been processed and the validity of the documentation subjected to appropriate due diligence.

A Financial Institution that opts to rely upon the status designated for the Account Holder in the shared account system, without obtaining and reviewing copies of the documentation supporting the status, must be able to produce upon request by HMRC all documentation (or a notation of the documentary evidence reviewed, if the Financial Institution is not required to retain copies of the documentary evidence for AML purposes) relevant to the status claimed.