Additional money laundering checks for individual pensions

26 January 2021
We’re adding some additional checks to further tighten our money laundering controls needed to comply with the Fourth Anti-Money Laundering Directive (4AMLD). These may impact your clients' plans.

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, or
  •  they live 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 happens if we don’t receive the required evidence?

As per our current process, we’ll start to process the application, but we won’t apply the money 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.