Additional money laundering checks for ongoing servicing to workplace pensions

12 February 2021
We’re adding some additional checks to our ongoing servicing of workplace pension schemes. This will further tighten our money laundering controls needed to comply with the Fourth Anti-Money Laundering Directive (4AMLD) and may impact your clients' schemes or plans.

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:

  • Beneficial owner
  • Director
  • Trustee
  • Third party payer
  • Power of Attorney
  • Court of Protection

Bank account validation

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:

  • Bank statement
  • Copy of a bank account passbook
  • Crossed out cheque, verifying account details
  • Bank pay in slip

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.

AML checks

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:

  •  the electronic check fails,
  •  an individual opts out of us completing an electronic check
  •  they live outside the UK, or
  • the company is registered outside the UK.  

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.

What will trigger AML checks?

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:

  • The risk level of a country that any party named on the plan is resident in
  • A third-party payer having an indirect relationship to the scheme
  • Transfer payment over £2 million
  • Single contribution over £200,000

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.

What about third-party payers?

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

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.

What happens if we don’t receive the required evidence?

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.


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The Royal London Mutual Insurance Society Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The firm is on the Financial Services Register, registration number 117672. It provides life assurance and pensions. Registered in England and Wales number 99064. Registered office: 55 Gracechurch Street, London, EC3V 0RL.