Enhanced verification is generally required when a client is identified as high risk. The following provides a high-level overview of the requirements:



Australia

In Australia, Enhanced verification is generally required where:

  • it is determined that the money-laundering or terrorism financing risk is high; 

  • the client is, or has a beneficial owner who is, a foreign politically exposed person;

  • a suspicion has arisen for the purposes of section 41 of the Act (suspicious matter reporting obligations); or

  • the client is transacting with a party located in a prescribed foreign country.

Please see the full list of qualifying circumstances in AML/CFT Act Section 15.9.




New Zealand

In New Zealand, Enhanced verification is generally required where the client is:

  • a trust;

  • a company with 1 or more nominee directors, or which has shares in bearer form;

  • a limited partnership with nominee general partners; or

  • determined by the customer to be high risk, e.g. the client is a politically exposed person.

Please see the full list of qualifying circumstances in the AML/CFT Act Section 22.



United Kingdom

In the United Kingdom, Enhanced verification is generally required where the client is:

  • resident in a geographical area of high risk; 
  • a vehicle for holding personal assets;
  • a company with 1 or more nominee directors, or which has shares in bearer form; or 
  • determined by the customer to be high risk, e.g. the client is a politically exposed person.

Please see the full list of qualifying circumstances in Reg 33 MLR 2017.