Verifying Company Orders (Paused & Dailies)

This document aims to provide a comprehensive guide to identifying which individuals within a company order we require to verify, and the level of verification required in each instance.  This guide applies both to new company orders which are “paused” prior to incorporation, and existing ones being processed through “dailies”.   Who do we need to verify?   As a general rule, there are 4 main categories of individuals whose identity we are obliged to verify for AML purposes.  These are:   Our customer – This includes the named account holder, the payment card holder, and any individual who subsequently presents as the main contact for dealing with the order.  Normally, these will all be the same person, however where they are different, all individuals meeting these criteria should be verified.   The Ultimate Beneficial Owner(s) – This is defined as any natural person (i.e. human) who ultimately owns or controls – directly or indirectly – in excess of 25% of shares in the company.   Any Director using our Service Address   Any other individual who is listed as a PSC under the 4th Condition – “Holds Significant Influence or Control” – who is not otherwise covered by the categories above.   EXCEPTION:  Where an order contains an individual from a High-Risk Jurisdiction, according to our internal risk register, all officers and shareholders must be verified (within reason).  If in doubt as to what is reasonable in this scenario, please seek advice from management.   2. How do we identify those individuals in these roles?   Customer – to identify our customer, check the account holder name present on Efiling.  To check whether the payment card holder is different to the account holder, open the inbox callback@brand.co.uk in Office365, and search the account contact email address.  This should find the relevant order and denote the cardholder’s details.   Shareholder – For paused incorporation orders, the shareholder details should be clearly denoted in the company overview.  Where multiple shareholders are present, click “structure” in order to view the breakdown and share distribution, so as to identify those holding in excess of 25% of shares.   For dailies, the structure in the company overview may not always be accurate, and care should be taken to ensure the correct current structure is identified via Companies House. To do this, first check if the company authentication code has been imported into Efiling.  This will be present in the company overview.  If so, click on “Companies House Data” under “Quick Tasks” and scroll to the bottom.  The correct company structure will be shown branded with the Companies House Logo.   Where the authentication code is not present on Efiling, search for the company at Companies House, and navigate to “Filing History”.  Filter categories by “Confirmation Statements / Annual Returns” and then look for the most recent Confirmation Statement with updates.  Continue to do this until you either find a Confirmation Statement detailing the current share distribution, or you arrive back at the incorporation document, meaning no changes have been made since the company was formed.   It is also recommended to review the “People” tab, to ensure that the listed officers and PSCs appear consistent with the identified company structure.  Where obvious discrepancies are present, this should be escalated to senior compliance colleagues to review.   Directors with Service Address   From the company overview in Efiling, click “structure” and review the Officers.  If the address listed under “Service Add.” is either our London or Glasgow Office address, the director in question will need to be verified.   3. What do we need to do to verify our clients?   There are 3 primary levels of due diligence: Simplified Due Diligence Standard Due Diligence Enhanced Due Diligence   Simplified Due Diligence is applied only in very rare circumstances, wherein our customer has been verified by us as being regulated for AML purposes themselves, and are purchasing incorporation-only orders with no address or other renewable services.  This enables us to process the orders with no further checks.  Clients who are verified as regulated int his manner are still subject to Standard Due Diligence where their orders contains renewable services.   Standard Due Diligence involves the running of a digital identity check using Efiling’s MLC Review, or the external CreditServe platform.  This check runs the client’s personal details (name, DoB, home address) against several external databases in order to match these to a reliably existent individual.   Enhanced Due Diligence involves the provision of either manually or digitally certified photographic ID, alongside a recent proof of address document in order to confirm the client’s details.    4. When do we apply Standard vs Enhanced Due Diligence   The level of Due Diligence we apply is determined predominantly by the services purchased in any given order.   Where an order contains any of the following services, Enhanced Due Diligence should be applied to both the customer(s) and the UBOs:   Business Address Service Full Company Secretary Service   All other order types and services will be subject to Standard Due Diligence.   PLEASE NOTE:  As digital ID checks can only currently be run on UK residents, all officers who meet the criteria outlined in (1.) and who reside outwith the UK will be subject to Enhanced Due Diligence as standard, regardless of the risk level of the order or the services purchased.     5. How do we Carry Out Standard & Enhanced Due Diligence?   Standard Due Diligence To carry out standard due diligence (digital check), one must first navigate to the company overview of the order in question on E-Filing.  Thereafter, they should select “View Order > MLC Review”. This should then bring up a list of all customers, officers and shareholders within the company. Ensure that the appropriate brand for the order in question is selected on Efiling, and then press “view” next to the first individual to be verified.  This will bring up the individual’s personal details. Scan these details to ensure that they make sense (i.e. the date of birth is plausible, and the home address is not obviously a commercial premises).  Make any reasonable adjustments to formatting and then scroll down to the “MLC Checks” options. Here, we should run 3 checks:   IVS – this is the ID verification check, and will return one of 4 possible results:   Green TwoPlusTwo – This is a full pass. Orange TwoPlusOne – This is a partial pass, but in 99% of cases can be accepted. Orange OnePlusOne – This is a partial pass but is not considered reliable and so should be recorded as a Fail. Red Fail – Fail   If, and only if, the check passes – result (i) or (ii) – then proceed to:   2. Politically Exposed Persons (PEPs) & 3. Standard international Sanctions (SIS) In both instances, no results is the desired outcome.  However, where matches are presented, these should be escalated to senior compliance colleagues to review.   If an officer passes all 3 checks, then we should select “Save and Verify” to confirm this result.  The officer has now passed our checks and appropriate notes should be left across the MLC Page, Company Overview page, and Customer Page (customer only) of Efiling.   Where the officer fails these checks, appropriate notes should be left across the pages outlined above, and the officer should then be subject to the Enhanced Due Diligence Process instead.   Enhanced Due Diligence   For clients subject to Enhanced Due Diligence, an email requesting their certified ID and proof of address should be issued to the account holder at their registered contact email address. For paused orders, this email should be issued via Zendesk, and the template “(Brand) – Team – Address Services” or “(Brand) – Team – No Address Services” used, depending on whether or not the order in questions contains address services. The tickets should be assigned to Hayley Thomson – with the exception of those containing clients based in Turkey, which should be assigned to Niviena Kharlanova – and all bespoke information should be input manually for each email, including the Company Name, Customer Name, and the names of those for whom information is being requested. Once sent, an individual Credas invitation should be issued for each individual listed, and should be issued from either Hayley or Niviena’s appropriately branded account. Please Note: All Credas Invitations should be issued to the account holder’s email address, even if there are multiple individuals involved.