Client Due Diligence - Guide For Individuals
What is Client Due Diligence?
In many jurisdictions, including Jersey, legislation has been introduced that requires firms when taking on clients, or handling client business to have procedures in place to verify a client’s identity and their source of funds, this is called Client Due Diligence (CDD). Viberts is regulated by the Jersey Law Society and registered with the Jersey Financial Services Commission (JFSC). This requires us to gather certain information and obtain copies of certain documents to prove the identity of our clients. This is also required to comply with anti money laundering legislation.
We are aware that due diligence requirements are not easy to understand so we have produced this guide to assist you. If you require any further help, please do not hesitate to contact us.
SECTION 1: Documentation you will need to provide us for CDD
In order to comply with CDD requirements, all clients are required to provide the following original documents or certified copies:
- Signed terms of engagement letter;
- A current passport or driving licence;
- A recent utility bill or bank statement that shows current home address which is not more than 3 months old;
- Evidence for source of funds (see section 3 for requirements);
If the documents being provided are copies, they will need to be certified as per instructions in the additional notes section. An example of certified copies is shown below.
If you are unable to provide the above documents, please contact us for further guidance.
SECTION 2: Property clients only – additional CDD documentation if purchasing property in Jersey
If you are a client of our property team, you will need to provide the following additional items:
- A valid Jersey Registration Card which can be obtained from the Social Security Department (left image). Older cards are no longer valid – (below image);
- Confirmation as to the type of ownership you require by completing the joint ownership declaration form enclosed with your terms of business letter.
SECTION 3: Providing evidence for source of funds
In order to complete your matter/transaction we require documentary evidence relating to any funds you send to Viberts. For example if you are purchasing a property for £500,000 and you have a mortgage agreed for £400,000 with the balance being covered by £100,000 cash, we will require from you, confirmation as to how you acquired the £100,000.
For example this could be:
An accumulation of savings – for which we will require:
- A copy of a current bank statement (dated within the last 3 months) showing your name, account number and the current balance;
- We may also need a reference from the Bank which holds the account.
Cashing in a pension policy – for which we will require:
- A copy of the communication with your pension provider with regard to part payment of the pension policy and the amount to be paid to you by the pension provider;
- A copy of your bank statement showing your name, address, account number and those part pension monies being paid into your bank account; and
- If the pension monies were paid into your account 3 or more months ago, we will also require a copy of your current bank statement (dated within the last 3 months) showing your name, address, account number and the current balance.
A cash gift – for which we will require:
- A letter from the person/s gifting the monies to you which clearly records that the monies are a gift from them to you;
- In respect of gifts of £20,000.00 and above, then the person gifting the monies to you will have to provide evidence as to how they acquired the funds.
- A copy of that person/s bank statement (dated within the last 3 months) showing there were sufficient funds to pay the cash gift to you (showing their name, address, account number and the current balance);
- A copy of your bank statement showing your name, address, account number and the monies being paid into your bank account from the person/s providing the gift to you; and
- If the gifted monies were paid into your account 3 or more months ago then we will also require a copy of your current bank statement (showing your name, address, account number and the current balance and which statement is dated within the last 3 months).
Funds from the sale of a property – for which we will require:
- A copy of the financial statement you received from the law firm acting for you in relation to the sale of the property. The statement must show the amount of the monies being transferred to your bank account;
- A copy of your bank statement showing the money referred above being credited to your account;
- If the monies referred to above were paid into your account 3 or more months ago then we will also require a copy of your current bank statement (dated within the last 3 months) showing your name, account number and the current balance.
IMPORTANT: Please ensure we receive a bank statement of the account you are sending the funds from showing your name, address, account number and a balance which includes the funds you are sending us.
This list of examples is not exhaustive. If you have acquired monies you are using for your transaction by any other means please contact us to establish what evidence is required.
The CDD guidelines above are a minimum requirement, and in some cases, we may be required to ask you for additional CDD information before we can process your matter.