Who is the customer, and who is acting for them?
Separate the legal customer from the person communicating with your firm. An individual acting on behalf of a customer brings an additional question: are they authorised to do so?
For a company, identify the relevant beneficial owners and take the required measures to verify them and understand ownership and control. Do not assume the person completing an identity journey answers every question.
HMRC: required customer due diligence measuresWhy is the customer using your services?
The purpose and intended nature of the relationship help the firm understand what it expects to see. That context belongs alongside identity information rather than being inferred from a screening status.
For example, record which entity has engaged your practice, which service it needs and who is giving instructions. These are useful prompts for organising the case, rather than a complete checklist for every engagement.
HMRC: required customer due diligence measuresWhat changes when the case needs more attention?
An inconsistency or unclear ownership chain is a question to resolve. A higher-risk case may require enhanced due diligence, additional evidence or escalation under the firm’s procedures.
Do not force every case into the same upload sequence. Decide what information would resolve the issue, request it clearly and keep the explanation with the decision.
HMRC: your AML responsibilitiesWhat happens after onboarding?
A relationship can change. New ownership, different instructions or unusual activity may call for a fresh look at the customer information and risk assessment.
A useful working file separates the original evidence, subsequent updates and the firm’s decisions. AMLCode’s onboarding report is designed to contribute to that file; it does not by itself carry out the firm’s ongoing monitoring.
HMRC: your AML responsibilitiesAre KYC and CDD the same thing?
“Know your customer” is often used as a broad industry term. Customer due diligence is the more specific regulatory concept used here. Check the actual measures a service includes rather than relying on either label.
This is a general introduction. Use current legislation and the guidance relevant to your services and supervisor when setting your firm’s procedures.