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HMRC internal manual

Money Laundering Regulations: Registration

Fit and Proper Test: Documentary evidence of identity

If we cannot confirm the customer’s identity from the information provided on the application form we will ask them to provide documentary evidence to confirm their identity.

If identity is to be verified from documents, this should be based on:

  • Either a government issued document which incorporates:

    • The customer’s full name and photograph, and
    • either his residential address;
    • or his date of birth

Government-issued documents with a photograph include:

* Valid passport
* Valid photo card driving licence (full or provisional)
* National ID card (for non-UK nationals)
* Firearms certificate or shotgun licence
* ID cards issued by the electoral office for Northern Ireland

As customers are non-face to face we must have a certified copy of these. This means that an independent professional person has looked at the person in front of them and has certified that they are the person on the passport. See MLR2R5500 for examples of an independent professional person.

  • Or a government issued document (without a photograph) which incorporates:

    • the customers full name,

    supported by secondary evidence of ID,


    • government-issues or issued by a judicial authority,
    • a public sector body or authority,
    • a regulated utility company,
    • or another FSA regulated firm in the UK financial services sector, or in a comparable jurisdiction,

which incorporates:

* The customer’s full name, and
* either his residential address
* or his date of birth

Government issued documents without, a photograph include:

* Valid old style full UK driving licence
* Recent evidence of entitlement to a state or local authority-funded benefit, tax credit, pension, educational or other grant

Other documents include:

* Instrument of a court appointment
* Current council tax demand letter or statement
* Current bank or credit/debit card statements (but not ones printed off the Internet)
* Utility bills (but not ones printed off the Internet)

The examples of other documents are intended to support a customer’s address, and so it is expected that they will have been delivered to the customer through the post, rather than being printed from the Internet.