Identification and verification under the money laundering regulations: Problems with compliance

The paper analyses the identification requirements imposed on financial institutions by the UK Money Laundering Regulations 1993 and the related guidance given by the Joint Money Laundering Steering Group. The paper seeks to distinguish between what is actually required by law from what is or may be good practice: it argues that in some respects the guidance goes beyond what is legally required. The paper deals in particular with the operation of the Regulations where business is introduced to the financial institution by an intermediary, or where the applicant for business is an agent, trustee or a company.