Anti-Money Laundering Requirements

If you’ve opened a bank account or made an investment recently, you would have been asked to provide a copy of your passport or driving licence and a recent utility bill. The reason for this is anti-money laundering requirements; ensuring that you aren’t trying to launder illegally earned money or finance terrorism. As a financial advisor, I deal with a number of banks and get very frustrated as each seem to have their own rules. So I read the Guidance on Identification and Verification Procedures to see what it says compared to what is actually applied.


The Designated Persons i.e. bank, insurance company, have to verify the following information to identify an individual:

  1. Name
  2. Date of Birth
  3. Current Address
  • The standard approach in the Guidelines is the “one plus one” approach – one photographic ID to verify your name and date of birth and one non-photographic ID to verify your current address.
  • Additional identification verification may be required depending on the risk assessment of the individual.
  • The photo ID must be current i.e. not expired and valid.
  • Non-photo ID should be of a recent date, i.e. not greater than 6 months, except in the case of an official document known to be issued only or typically at fixed intervals of more than 6 months, in which case such documents may be accepted during that period, to a maximum of 12 months e.g. car tax.
  • Non-photo ID – Current local authority documents, bank or credit card statements and utility bills can be printed from the internet.


The Guidelines lets each Designated Person to decide on a risk basis which of these types of documents it considers appropriate. With having the scope to assess their own risk basis, the reality is very different from the Guidelines

  • No company will accept statements/ utility bills that are more than 3 months old.
  • No one accepts an official document that is only issued once a year (unless issued within the last 3 months).
  • Despite not being a requirement, most companies also look for proof of your PPS number.
  • Some companies require one utility bill/ statement, others two, even if all documents are certified by a suitable person.

Tips to satisfy Anti-Money Laundering Requirements

  • Do not argue with their requirements. There is no point.
  • Photo ID must be clear and your face is clear. Colour photocopies are better than black & white.
  • Photocopy the full driving licence (if the old type) and front and back (if the new one). For passports, photocopy the opposite page to the photo as well. All the codes at the bottom must be on the photocopy.
  • Avoid internet print outs, although it generally accepted to allow pdfs printed from electronic statements.
  • Make sure the statement/ utility bill is within the last 3 months.
  • In a lot of households, utility bills are held in one persons name. It is a good idea to hold them in both persons name. To do this, you have to phone the utility company when both of you are present for verification purposes.

It would make everyone’s life easier if the banks and insurance companies talked and adopted universal requirements so the rest of us didn’t have to second guess what they would accept.

If you have any questions, please contact me directly at