This means the following checks may take place when you or your client request certain changes to their scheme or plan.
Identity checks for workplace pensions cover the plan holder and all connected parties such as:
We need to verify that the name and address of the person or company making a contribution matches the bank details provided.
We’ll do this electronically and, if the verification fails, we’ll ask you for more evidence. This can be any of the following:
The evidence must include name, address, account number and sort code. We won’t accept a list of transactions downloaded from online banking.
We can only accept an email where the attachment is a PDF download which looks exactly like a postal statement. International equivalents will always be acceptable for these cases.
Copies of these documents are acceptable, as long as they’ve been certified by an appropriate person, such as a solicitor or notary or a bank or building society official.
Please note – Certain bank accounts, including any opened and registered before 1989, may fail our checks, so we may request further evidence. Sending this evidence upfront will allow us to progress the application.
When we need to carry out AML checks for individuals, we’ll aim to do this electronically. However, we’ll request additional proof of identity if:
It’s important to note that the reality of meeting our regulatory requirements means we’re likely to be asking for additional evidence on a regular basis.
If the client or any connected parties don’t want us to carry out an electronic check, they’ll need to provide evidence with the application form.
If they opt out of us completing an electronic check, they’ll need to send us two documents confirming their identity, such as a passport or driving licence and a recent utility bill, along with the completed application form.
Certain changes to existing schemes or plans, will trigger AML due diligence checks on individuals and companies.
We’ll complete what’s called a Customer Risk Assessment (CRA) to determine if a customer or company is at an increased risk of money laundering. The triggers we’ll look at are:
For any schemes or plans with a high risk rating, we’ll carry out enhanced due diligence AML checks on all parties named on the scheme or plan, including company checks and the beneficial owners or persons of significant control within these companies, and we may request further information from you.
If contributions are being made by a third party on behalf of the employer, we’ll also carry out identity checks to verify the beneficial owner of the third-party business.
A beneficial owner is someone who controls 25% or more of a business.
If there are no beneficial owners, we’ll need to carry out these checks on key persons relating to the business. A key person is someone who can make or influence decisions around the business.
The table below shows the different levels of checks that apply, depending on where the company is registered. We’ll contact the adviser if any of these checks fail.
UK owned |
Internationally owned |
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Beneficial owner(s) will be confirmed via Companies House and we’ll cross-check this against the application form. |
Low risk country |
Medium risk country |
High risk country |
Prohibited country |
Email confirmation of beneficial owner(s) is enough. No further checks are needed. |
Beneficial owner(s) need to be verified using documentary evidence. |
Beneficial owner(s) need to be verified using documentary evidence then this will be passed to the Centre of Excellence team for a decision. |
The application should be declined. |
We’ll perform Politically Exposed Person and Sanctions screening against any connected parties associated with the scheme or plan. We might also need to ask you to give us additional documentary evidence, where required.
As per our current process, we’ll start to process the request, but we won’t complete it until we receive the evidence we need.