:: HAFIZ BROS MONEY TRANSFER LTD ::

Hafiz Bros Ltd.
107 Albert Drive, Glasgow, G41 2SU.
Policy Statement and Risk Assessment

Table of Contents
Policy Statement
Page
What is money laundering? 2
Commitment to anti-money laundering legislation 2
Employee Training 2
Prompt reporting of suspicious activity 2
Summary of company’s approach to assessing and managing its money
Laundering and terrorist financing risk 3
Summary of company’s procedures for carrying out ID and verification
Of that ID 3
Company’s customer due diligence measures 4
Ongoing monitoring of business relationships 5
Monitoring and managing compliance 5

Risk Assessment

Customer Profile 6
Risk identification
- Money transmission business 7-8
- Bureau de change 8-9
- Cheque encashment 10
Risk factors and response 11-14
Customer due diligence: policy on acceptable ID and satisfactory
Evidence 15-16
Customer due diligence: business relationships 17
Ongoing monitoring of business relationships 17-18
Monitoring the risk 18
Internal controls and communication 19
Monitoring and managing compliance 19
Suspicious activity reporting 19-22
Record keeping 23
Training 23-25
Appendix 1: ID Requirements for Send and Receive Money Transfers 26-28

Policy Statement

Hafiz Bros Ltd, herein referred to as; the Company; recognize their legal obligations to have procedures and controls in place to deter, disrupt and detect money laundering and terrorist financing.

What is money laundering?

Money laundering is any transaction or series of transactions undertaken to conceal or disguise the nature and source of funds that have been obtained from illegal activity. The main objective of the money launderer is to transform ‘dirty’ money into seemingly clean money or other assets in a way to leave as little trace as possible of the transformation. Examples of illegal activities that often involve money laundering are drug trafficking, terrorism, fraud, bribery, robbery, embezzlement and illegal gambling.

Commitment to anti-money laundering (AML) legislation

The company totally supports the government’s anti-money laundering and combating terrorist financing measures. The company and its staff adopt a zero tolerance approach to money laundering and terrorist financing and are committed 100 % to ensuring that the business is not used by money launderers and terrorists, and that any such attempts or suspicious activity are promptly reported to the relevant authorities.

Employee training

The company is committed to ensuring all relevant staff are made aware of the law and their obligations under it and are regularly trained in how to recognize suspicious activity. All new staff will undergo training before dealing with the public and all existing staff will undergo continuous training. Staff will undergo follow-up training every 6 months.

Prompt reporting of suspicious activity

The company recognizes the importance of staff promptly reporting suspicious activity. Any suspicious activity must be reported immediately to the nominated officer, Mr. Amir Shahzad, who will make a decision as to whether a disclosure be made to the Organized Crime Agency.

Summary of company’s approach to assessing and managing its money laundering and terrorist financing risk

The company has adopted a risk-based approach toward the threat of money laundering and terrorist financing. This requires a number of steps which are to:

• Identify the money laundering and terrorist financing risks that are relevant to the business.

• Assess the risks presented by

The types and behavior of customers

Products and services offered

Delivery channels, e.g. cash over the counter, e.g. location of business premises, source or destination of customers’ funds

• Design and implement controls to manage and mitigate these assessed risks, e.g. customer ID and verification, and customer due diligence

• Monitor and improve the effective operation of these controls and

• Record appropriately what has been done, and why.

Summary of company’s procedures for carrying out ID and verification of that ID

For money transfer

There are stringent procedures in place for sending and receiving money by money transfer, which are detailed in Appendix 1.

For Individuals

ID
When checking ID of individuals the business must obtain their name, address and date of birth.

Verification
Obtain verification of ID from identity documents, e.g. passport or driving license plus secondary identification which shows individuals name and current address, e.g. utility bill or bank statements.

For limited companies

ID
The company should obtain the full name, registered number and registered office in country of incorporation of corporate customer. The names of all directors and names of any beneficial owners holding over 25% of the limited company should be obtained.

Verification The company should verify the identity of the corporate entity from either a search of the relevant company registry or a copy of the company’s certificate of incorporation.

Company’s customer due diligence measures
Customers due diligence measures must ascertain the intended nature and purpose of the business relationship and also to collect information on the customer, their business and risk profile to allow ongoing monitoring of the business relationship to ensure that transactions undertaken are consistent with the knowledge.

Due diligence measures must be applied:
• When establishing a business relationship
• When carrying out an occasional large transaction (i.e. involving £2,000 or euro/foreign currency equivalent or more)
• Where there is a suspicion of money laundering or terrorist financing
• Where there are doubts about previously obtained customer identification information
• At appropriate times to existing customers on a risk-sensitive basis

Ongoing monitoring of business relationships
It is essential that there is ongoing monitoring of business relationships which means

• Ongoing scrutiny of transactions (including the source of funds) to ensure that the transaction are consistent with the company’s knowledge of the customer, their business and risk profile

• Ensuring that the documents, data or information held evidencing the customer’s identity are kept up to date.

Monitoring and managing compliance
The Amir Shahzad is responsible for ensuring that appropriate monitoring processes and procedures are established and maintained.
Regular audits and exercises that test the procedures will be carried out on a regular and ongoing basis.

Risk Assessment
Risk assessment carried out 25 OCT 2010.
Customer profile

Percentage of customers

In a business relationship 25%

Regular customers doing one-off transactions 45% Passing trade 30%

How are customers introduced to the business?

Through recommendation/word of mouth 75%

Through advertising 25%

Off the street passing trade 5%

Other sources 5%

Are there any non face-to-face customers? No

Are there any potential Politically Exposed Persons? No

General description of usual types of customer and Mainly individuals send
Purpose of transactions money to families in Pakistan

Any significant customers outside normal No
Customers profile?

What is percentage of cash transactions? 90%

Risk identification

Money Transmission Business

Money transmission business are faced with a high risk that they will be used to launder the proceeds of crime of transfer monies that finance terrorism. The risk can vary according to customers, delivery channels and geographical destination of funds.

Factors that increase the risk of money laundering or terrorist financing are

• High value remittance

• Cash funding and cash payouts

• The country to which money is being transmitted may have a higher crime rate or likelihood of money laundering or terrorist financing

• Dependence on an agent for customer contact

• Non face to face transactions

• New customer with no previous relationship with money transmission business looking to undertake larger transactions

• Lack of knowledge regarding the origin or destination of funds

• Lack of a meaningful purpose for the transaction Factors that decrease the risk of money laundering or terrorist financing are

• Low value remittances

• Funding from and payment into bank accounts

• The using of accounts to keep track of customer transactions

• The ability to track linked transactions and identity transaction patterns

• The ability to freeze transactions after they have been initiated

• The countries in which the product operates are regarded as having a lower risk of crime, money laundering or terrorist financing

• Knowledge of the recipient as well as the sender of funds

• Face to face contact with the customer

• An ongoing relationship with the customer

• Knowledge of the origin of funds

• A stated purpose for the transaction

The ID requirements for sending and receiving cash for money transfer quite stringent, which helps to mitigate the risk. However, there is millions of money transfer transactions conducted each month and the likelihood of a particular transaction actually involving the proceeds of crime is very low.

The risk is in failing to identify customers or situations where the level of foreign exchange activity is higher than one would expect from that segment of the business or unusual or inconsistent in some other way. In such circumstances there is justification for looking more closely at whether the customer may be laundering money or financing terrorism.

Factors that increase the risk of money laundering or terrorist financing are

• Cash transaction: cash is the mainstay of much organized criminal activity. The objection of the first stage of money laundering is to move the criminal cash into the financial system. They will often seek to exchange cash in one currency for foreign currency or vice versa.

• Speed and size of the transaction: Money launders normally want to move funds quickly in order to avoid detection. This is easily done in large one-off transactions.

• Split transaction: Money launderers may look to split a large transaction into several smaller one with the intention of avoiding anti money laundering controls. Such known as ‘smurfing’ can occur within one location.

• Customer operates within a high risk sector: some money launderers will be proprietors of cash-based businesses such as restaurants, pubs, casinos, taxi firms, beauty salons and amusement arcades. The aim here is to mix ‘dirty’ money with ‘clean’ and so muddy the trail.

• Customer operates a Money Service Business.

• Customer undertakes transactions that make no commercial sense or do not match profile of customer. This will also include significant and unusual changes to a customer’s established pattern of behavior.

• The customer is not the beneficial owner of the funds and carries out transaction on behalf of third party or parties.

Factors that decrease the risk of money laundering or terrorist financing are

• The transaction is funded by a cheque, debit/credit card or CHAPS payment.

• Transactions are conducted for a customer on a regular basis and the client is known to the organization.

The company’s risk-based approach has been designed to ensure that it places an emphasis within its strategy on deterring and disclosing in the areas of greatest perceived vulnerability.

The provision of currency and the ability to convert currencies is a particular area of risk. Most customers both personal and business will have a legitimate need to convert currency. However, the risk is in failing to identify customers or situations where the level of foreign exchange activity is higher than one would expect from that particular segment of the business or unusual or inconsistent in some other way. In such circumstances there is justification for looking more closely at whether the customer may be laundering money or financing terrorism.

Cheque Encashment

Cheque cashers are not normally exposed to large scale money laundering because the flow of cash in a cheque cashing transaction is in the opposite direction to that required by most money launders. Also is in the very nature that a cheque is traceable, gives us reason to believe that large scale money laundering is unlikely. Outside customers with whom the bureau has a business relationship, only cheques for small sums are cashed, and ID documents with address verification are kept on file. Whilst the risk money laundering is minimal, the possibility is not totally ignored.

Risk factors and response

The risk factors that are relevant to the business and action that will be taken to mitigate these risks are listed below

Risk factor Explain why and how the factor does or does not apply What procedures are in place to mange and mitigate the risks

Customer types and behavior

Customers with businesses that handle large amounts of cash Does not apply If applied ID documents on account file with verification. Ongoing monitoring of transaction to ensure there is no inconsistency with our knowledge of business
Complex business structures Not applicable at present Ongoing monitoring
Potentially Politically Exposed Persons Does not apply If applies ID documents on account file with verification and ongoing monitoring of every transaction. If anything strange report to SOCA
High risk jurisdictions Applies small number of money transfer transaction ID documents on account file with verification. Ongoing monitoring of transaction to ensure there is no inconsistency with our knowledge of business
Customers who are not local to the business It does apply Any non local customers who exceed the € 1,000 limit must produce verifiable ID and account for why they are cashing money so far from home

Risk factor Explain why and how the factor does or does not apply What procedures are in place to mange and mitigate the risks
New customers carrying out large transaction Applies rarely Must produce verifiable ID and account for the source of their money
Customers carrying out regular large transactions Applies rarely Must produce verifiable ID and account for the source of their money
Number of transactions below the amount requiring ID checks carried out by same customer within a short space of time Applies rarely Must produce verifiable ID and account for the source of their money

A number of customers sending payments to the same individual Applies occasionally Must find out reason why, and produce verifiable ID and account for source of their money
Non face-to-face customers Does not apply Must produce verifiable ID which has been certified and account for the source of their money
Situations where the source of funds not established Reports to Amir SHAHZAD and if necessary to SOCA

Product/transaction types
Complex or unusually large transaction Not yet occurred Must produce verifiable ID and account for the source of their money and there must be a good reason for complexity
Unusual patterns of transaction which have no apparent economic or visible lawful purpose Report to Nominated Office and if necessary to SOCA

Risk factor Explain why and how the factor does or does not apply What procedures are in place to mange and mitigate the risks
Uncharacteristic transaction which are not in keeping with the customer’s activities Can occur Report to Amir SHAHZAD to decide what steps to take

Sudden increase in business from existing customer. Applies occasionally Question why If answer does not stack up report to Amir SHAHZAD for further action
A high level of transaction for amounts just below the amount requiring ID checks Can happen but easily spotted. Lower limits for ID checks and report to Amir SHAHZAD for further action

Delivery channels

Large cash transaction Must produce verifiable ID and account for the source of their money
Occasional or one-off transaction as opposed to business relationships Must produce verifiable ID and account for the source of their money

Business organization / geographical area of operation

Large numbers of branches 2 branches No extra risk
Large number of agents Occasionally transfer funds for other MSBs No extra risk
Geographical location of operation Albert Drive is in Glasgow with a fluctuating and migrant population with attendant risks Stringent ID checks in place and high awareness of suspicious activity factors
Number of employees and turnover of staff 4 employees – low turnover of staff business Any employees will be well trained to recognize suspicious activity

Risk factor Explain why and how the factor does or does not apply What procedures are in place to mange and mitigate the risks
Money sent to or received from areas known to have high levels of criminality or terrorist activity Applies to small number of money transfer transaction ID documents on account file with verification. Ongoing monitoring of transaction to ensure there is no inconsistency with our knowledge of customer

Customer due diligence: policy on acceptable ID and satisfactory verification

Arrangements for Dealing with Money Transfer Transactions

All money transfer customers must register with company by providing passport or any other photo ID and a United Kingdom proof of address, and if customer does not have proof of address in own name, then they must fill in a third party proof of address form.

Procedure for customers conducting transaction in excess of € 1,000 and for all money transfers

1. Obtain name, address and date of birth of customer
2. Obtain two primary forms of ID or one primary plus one secondary form of ID

Primary forms of ID
a) Passport
b) Driving license
c) National ID card
d) Firearms certificate or shotgun license
e) ID card issued by the electoral office Northern Ireland

Secondary forms of ID include the following
a) Current bank statement
b) Current utility bill

Checks on ID evidence

? Check any photographs for likeness
? Check the date of birth compared to customer’s apparent age
? Compare spelling of names and addresses on different identification documents
? Compare customer’s signature with signature included in identification evidence
? Photocopy and check all ID evidences and record in account file

Arrangements for dealing with limited companies
Where the customer is a limited company you should identify the individuals you deal with and obtain details of the company’s:-
? Registered number, corporate name and any trading names used;
? Registered address and any separate principal trading address; and
? Business activity
The details should be checked by either a search of the relevant company registry or by a copy of the company’s certificate of incorporation. Record them in the account file.

Arrangement for dealing with cheque cashers

All cheque cashers should produce one primary form of ID plus one secondary form of ID
Primary forms of ID
a. Passport
b. Driving license
c. National ID card
d. Firearms certificate or shotgun license
e. ID card issued by the electoral office for Northern Ireland

Secondary forms of ID include the following
a. Current bank statement
b. Current utility bill

However there may be times when the company decides that a customer cannot reasonably meet the standard identification requirement and the provisions above cannot be met. The company may then accept as ID evidence, a letter or statement from an appropriate person who knows the individual, that indicates that the person is who they say. An appropriate person is an independent professional person who is not a relative or friend of the individual, for example:-

? Family GP
? Accountant
? Solicitor
? Civil servant
? Teacher
? Notary
? Post office branch employee
? Employer

Customer due diligence: business relationships

A business relationship is an arrangement between the company and a customer that anticipates an ongoing relationship between the two parties. This can be a formal or an informal arrangement.

When a business relationship is identified then the company must obtain the following information to understand the purpose and intended nature of the relationship

? Details of the customer’s business or employment

? Record of changes of address

? The expected source and origin of the funds to be used in the relationship

? Initial and ongoing source(s) of wealth or income

? The relationship between signatories and underlying beneficial owners

? The anticipated level and nature of the activity that is to be undertaken through the relationship.

ID and verification procedures are as above for transaction over €1,000 and money transfers.

Before commencing business, the company must decide if all the information of the customer and his/her sources of income make sense.

Ongoing monitoring of business relationships

Business relationships need to be monitored constantly by front line staff at each transaction and monthly by Amir Shahzad. Trigger events for possible money laundering and terrorist financing risks include

? A sudden increase in business from an existing customer
? Uncharacteristic transactions which are not in keeping with the customer’s known activities

? Size and frequency of transaction is not consistent with the normal activities of this business

? The pattern of transactions has changed since the business relationship was established

? Peaks of activity at particular times

? Unfamiliar or untypical types of customer or transaction

Should any of the above trigger events occur then front line staff should query the customer if they feel it is appropriate, or if not, pass the information onto the Mr. Amir Shahzad, who should make appropriate enquiries as to what is happening.
Every month front line staff must review all client information to ensure that records are up to date.

Fro any customers that are considered high risk, the Amir Shahzad should be informed of all transaction, in order that the company can act swiftly. If necessary.

Monitoring the risk

What analysis is carried out in respect of:

Number and size of transaction all transaction analyzed daily

Customer profiles Analyzed every 4 months

Patterns and fluctuation in trade Analyzed monthly for all business
Relationships and per transaction for
High risk customers

Suspicious activity all transaction analyzed for suspicious
Activity intuitively by front line staff

Internal controls and communication

All public facing staff report directly to the Mr. Amir Shahzad. Public facing staff can make decision based upon experience, but if any doubt they must act through the Mr. Amir Shahzad.

As new information comes to light or new legislation is enacted, all staff will be briefed as soon as possible. Staff will be trained upon commencement of duties before dealing with the public and will have follow on training every 12 months.

The Amir Shahzad will review and update risks and control every 4 months so that policies and procedures continue to effectively manage the risks.

All relevant information regarding policies or procedures will be communicated to relevant staff immediately.

Monitoring and managing compliance

The Amir Shahzad will ensure that appropriate monitoring processes and procedures are established and maintained. He will conduct regular audits and exercises that test that procedures are adhered to throughout the business.

Suspicious activity reporting

All suspicious activity should be reported to the Mr. Amir Shahzad.

It is essential to recognize the importance of front line staff awareness. Such factor as intuition, direct exposure to a customer face to face or on the telephone,
And the ability, through practical experience, to recognize transaction that does not seem to make sense for that customer, cannot be automated.

If staff is unsure whether consent for a transaction should be authorized, they should refer the matter to Mr.Amir Shahzad. If he is not obtainable, then staff must refuse transaction. A list of suspicious activity is listed below.

Mr. Amir Shahzad must decide if there are reasonable grounds to suspect money laundering. Before deciding to make a report to SOCA, Amir Shahzad will need to access all the business’s relevant records with regards to the customer. He will need to consider the level of identity information held on the customer and any information held on his personal circumstances, and review transaction patterns and volume through the accounts.

If the Amir Shahzad decides not to make a report to SOCA, the reason for not doing so should be clearly documented and retained on file. The following lists are not exhaustive but set out some of the main indications that a transaction is suspicious.

New customers and occasional or ‘one-off’ transaction:

? Checking identity is proving difficult

? The customer is reluctant to provide details of their identity

? There is no genuine reason for the customer using the services of an MSB

? A cash transaction is unusually large

? The customer is happy with a poor rate

? The customer is buying currency that does not fit with what is known about customer’s destination

? The cash is in used notes and/or small denominations and the customer request currency in large denomination notes

? The customer will not disclose the source of cash

? The explanation for the business and/or the amounts involved are not credible

? A series of transaction are structured just below the regulatory threshold for due diligence identity checks

? The customer has made an unusual request for collection or delivery

? Transaction having no apparent purpose or which make no obvious financial sense, or which seem to involve unnecessary complexity

? Unnecessary routing of funds through third parties.

Regular and established customers

? The transaction is different from the normal business of the customer

? The size or frequency of the transaction is not consistent with the normal activities of the customer

? The pattern of transaction has changed since the business relationship was established

? Money transfer to high-risk jurisdiction without reasonable explanation which are not consistent with the customer’s usual foreign business dealings

? Sudden increase in the frequency/value of transaction of a particular customer without reasonable explanation.

Example where customer identification issues have potential to indicate suspicious activity

? The customer refuses or appear reluctant to provide information requested

? There appears to be inconsistencies in the information provided by the customer

? The customer’s area of residence is inconsistent with other profile details such as employment

? An address appears vague or unusual

? The supporting documentation does not add validity to the other information provided by the customer

? The customer is in a hurry to rush a transaction through, with promises to provide the information later.

Example of activity that might suggest to staff that there could be potential terrorist activity

? The customer is unable to satisfactory explain the source of income

? Frequent address changes

? Media reports on suspected or arrested terrorists or groups.

Cheque encashment

? look out for low and consective cheque number as fictious companies may be set up for the purpose of cheque fraud

? A number of different people cashing cheques all of which are drawn on the same company, with an unfamiliar name

? There will be an indication of benefit fraud where people try to cash their benefit cheques and produce wages slips as ID or vice-versa where they are cashing their wages cheque and produce paperwork regarding job seekers allowance as ID

? In some circumstances there may be an indication of fraudulently obtained cheques where a person has a number of cheques drawn on different individuals, rather than company cheques, claiming to have done work for these people

? A sudden increase in cheque values

? A customer wants to cash a cheque which was made payable to them weeks

? It appear that there has been something added to the cheque after the time of issue, e.g. different handwriting is evident, value digits appear squeezed in Record -keeping
An account file must be set up for each customer with whom we have a business relation- ship, and for each large occasional transaction.

Copies of ID and verification must be kept on file and details of all transactions with that customer recorded.
All information used to set up a business relationship must be recorded and kept on the file.

Details of any suspicious activity, reports to Amir Shahzad and disclosures to SOCA must be kept on file.

Evidence of customer’s identity record must be kept for five years beginning on the date on which the occasional transaction is completed or the business relationship ends.

Records of transaction (weather undertaken as occasional transactions or part of a business relationship) must be kept for five years beginning on the date on which the transaction is completed.

All other records must be kept for five years beginning on the date on which the business relationship ends.

Training

Training of all relevant employees within the company plays a critical role in the successful implementation of any risk based approach to managing potential money laundering risks. All relevant employees must be aware of and understand the legal and regulatory environment in which they operate.

All employees are to be trained before commencing face to face dealings with the public, and thereafter to receive follow-on training every month.

Training to enable employees to recognize and deal with suspicious transactions should include:-

• The identity and responsibilities of Mr. Amir Shahzad ( or MLRO)

• The potential effect on the firm, its employees personally and its clients of any breach of the law

• The risks of money laundering and terrorist financing that the business faces

• The vulnerabilities of the business’s products and services

• The policies and procedures that have put in place to reduce and manage the risks

• Customer due diligence measures, and, where relevant, procedures for monitoring customers’ transactions
• How to recognize potential suspicious activity

• The procedures for making a report to Mr. Amir Shahzad.

• The circumstances when consent is to be sought and the procedure to follow

• Reference to industry guidance and other sources of information, e.g. Serious Organized Crime Agency, Financial Action Task Force.

All staff should be made aware that HMRC have the power to impose civil penalties on businesses that fail to comply with the requirement of the Regulations in respect of :

• Notification and registration requirements

• Customer due diligence measures

• Ongoing monitoring of a business relationship

• Enhanced customer due diligence and ongoing monitoring

• Record keeping

• Policies and procedures to prevent money laundering and terrorist financing

• Appointing a Amir Shahzad and internal reporting procedures

• Training of employees

There is no upper limit in regulation 42 on the amount of penalties. Penalties will be for an amount that is considered appropriate for the purposes of being effective, Proportionate and dissuasive.

Businesses can ask HMRC to review the decision to impose a penalty, or of the amount of the penalty, and the decisions to refuse or cancel registration. Penalty and the registration decisions can also be appealed to the VAT and Duties Tribunal.

MLR 2007 regulation 45 sets out the offence of failing to comply with the MLR 2007 obligations. Conviction under the MLR 2007 can incur up to 20 years’ imprisonment and/ or an unlimited fine.

Appendix 1: ID Requirements For Send and Receive Money Transfers

Customers must present ID on all receive transactions and when sending transactions over 600 pounds.

Receive Transaction 0-599.99

The following documents on their own can be accepted as proof of the customer’s name and date and place of birth
• Passport and one evidence of proof of address.
• National Identity Card
• Current UK photo-card driving license
• Resident permit issued to EU nationals by Home Office
• Home Office IND Application Registration card and one evidence of proof of address.
• Immigration Forms SAL 1 and SAL 2 (issued before January 2002) and one evidence of proof of address.
• Certificate of Registration issued by the police or customs and one evidence of proof of address.

If customer does not have any of above documents, then they must provide 2 documents; 1 proving their name and 1 proving their address.

They must provide 1 document from List A and 1 document from List B
LIST A

Documents to prove NAME LIST B

Documents to prove address
• Current full UK old style paper driving licence
• Birth certificate
• Building industry sub-contractors certificate issued by inland revenue
• Inland revenue tax notification (P45 and P60 is not acceptable)
• Firearms certificate
• Police warrant card
• UK forces ID card

• Utilities bill (no more than 3 months old )
• Local authority tax bill (for current year)
• Current full UK old style paper driving licence (if not used from List A)
• Bank, building society or credit union statement or passbook (no more than 3 months old) containing current address
• Most recent original mortgage statement from a recognized lender
• Solicitor’s letter confirming recent house purchase
• Local council rent card or tenancy agreement

Appendix 1: ID Requirement For Send and Receive Money Transfers

Send and Receive Transaction £600 - £1999.99

The following documents on their own can be accepted as proof of the customer’s name and date and place of birth
• Passport
• National identity card
• Current Uk photo-card driving licence
• Residence permit issued to EU nationals by home Office
• Home Office IND Application Registration card
• Immigration forms SAL1 and SAL2 (issued before January 2002)
• Certificate of Registration issued by the police or customs

If customer does not have any of the above documents, then they must provide 2 documents; 1 proving their name and 1 proving their address.

They must provide 1 document from list A and 1 document from List B
LIST A

Documents to prove NAME LIST B

Appendix 1: ID Requirement For Send and Receive Money Transfers

Send and Receive Transaction £2,000 - £5,000

For transaction over £2,000 customers must verify their full name, country, date of birth and address.

The must provide 1 document from List A and 1 document from List B

LIST A

Documents to prove NAME LIST B

Documents to prove address
• Passport
• National identity card
• Current UK Photo-card Driving licence (full or provisional)
• Residence permit issued to EU nationals by Home Office
• Home office IND card
• Immigration forms SAL1 and SAL2 (issued before January 2002)
• Certificate of registration issued by the police or customs
• Current full UK old style paper driving licence
• Birth certificate
• Building industry sub-contractors certificate issued by inland revenue
• Inland revenue tax notification (P45 and P60 is not acceptable)
• Firearms certificate
• Police warrant card
• UK forces ID card • Utilities bill (no more than 3 months old )
• Local authority tax bill (for current year)
• Current full UK old style paper driving licence (if not used from List A)
• Bank, building society or credit union statement or passbook (no more than 3 months old) containing current address
• Most recent original mortgage statement from a recognized lender
• Solicitor’s letter confirming recent house purchase
• Local council rent card or tenancy agreement
• Letter from a hostel manager confirming temporary residence
Letter from the matron of a nursing home or residential home