ANTI MONEY LAUNDERING & CUSTOMER DUE DILIGENCE COMPLIANCE

The Isle of Man Government has passed specific legislation and regulations regarding anti-money laundering and ‘customer due diligence’ compliance in accordance with Internationally accepted standards. These rules affect the acceptance of new business and monitoring of existing business.

These rules are further enshrined in the license conditions by which we operate our business and are therefore a fundamental part of us acting for you.

CGI takes these requirements seriously and every client must provide appropriate information and identification to meet these requirements. Failure to provide such information or inability for us to verify the authenticity will result in us not being able to continue to work for you.

CERTIFICATION OF DOCUMENTS

If you are unable to deliver original documents to CGI, we will be able to accept copies of them as long as the copies have been appropriately certified. Certification requirements are:

The certifier must be a lawyer, accountant, bank manager, notary public or consular official at a British Embassy or Consulate (the certifier must not be a member of your family).

The certifier must:

Sign and date the copy document.

Print his or her name clearly in capital letters underneath the signature.

State that it is a true copy of the original.

Indicate his or her capacity (i.e. lawyer, accountant etc.) on the document.

APPLICATIONS FOR BUSINESS

The following clearly explains the identification and verification documents required by CGI in order for us to establish a business relationship with you.

Individuals:

In order to confirm your identity we will require one of the following:

An original or certified copy of your passport; or
An original or certified copy of your driving license or armed forces I.D. Card; or
An original or certified copy of a Government issued National Identity Card

In order to confirm your name and address we will require one of the following:

An original rates, council tax or utility bill (gas, electricity or telephone but not a mobile telephone bill)
A reference from a lawyer, accountant or bank manager who knows you and who is known to CGI.

Finally, to complete our information we will require you to complete our Client Questionnaire and Personal Details Sheet.

Public Companies:

CGI is required to obtain the following documentation from all public companies applying for business (except companies classified as “Acceptable Applicants” (see below).

Certificate of Incorporation (or equivalent) or a certified copy thereof.
A copy of the company’s Memorandum and Articles of Association (or equivalent) certified by the Company Secretary.
A copy of the company’s last available accounts.
Evidence of the identity of the beneficial owners of the company, if practical. (Where there are many, as is common, evidence of identity will be restricted to beneficial owners with a large or controlling interest in the company.)
Evidence of the identity of at least 2 Directors and/or authorised signatories on the account.
A copy of the Board resolution authorising the opening of the account.
Certified copies of any Powers of Attorney or other authorities given by the Directors and which affect the operation of the account.
Completed copies of CGI’s Client questionnaire and Personal Details Sheets (as appropriate).

Private Public Companies:

CGI is required to obtain the following documentation from all private companies applying for business (except companies classified as “Acceptable Applicants” (see below).

Certificate of Incorporation (or equivalent) or a certified copy thereof.
A copy of the company’s Memorandum and Articles of Association (or equivalent) certified by the Company Secretary.
A copy of the company’s last available accounts.
Evidence of the identity of the beneficial owners of the company. (Where there are many, a list of shareholders should be provided and evidence of identity will be required on the principal beneficial owners.)
Evidence of the identity of at least 2 Directors and/or authorised signatories on the account.
A copy of the Board resolution authorising the opening of the account.
Certified copies of any Powers of Attorney or other authorities given by the Directors and which affect the operation of the account.
Completed copies of CGI’s Client Questionnaire and Personal Details Sheets (as appropriate).

Trusts:

CGI will require the following documentation for all applications for business from trusts.

Evidence of identity, where possible and practical, of the trustees, settlor(s), protector(s) and beneficiaries. (Where the trustee is a corporate trustee, the requirements are the same as for public and private companies.)
A copy of the trust deed or other documentation evidencing the fiduciary relationship or evidence of the proper appointment of the trustees.
A copy of the trustee’s resolution authorising the opening of the account.
Completed copies of CGI’s Client Questionnaire and Personal Details Sheets (as appropriate).

ACCEPTABLE APPLICANTS

The above identification and verification requirements may not be necessary for applicants for business classified as “Acceptable Applicants” (i.e. those who apply for business for their own benefit (i.e. not for the benefit of their clients). Also, CGI can in certain circumstances rely on identification and verification procedures carried out by those classified as “Eligible Introducers”. Acceptable Applicants and Eligible Introducers generally include the following:

Isle of Man licensed banking or investment businesses, building societies or corporate service providers.
Isle of Man authorised insurance businesses.
Certain other non-Isle of Man credit and financial institutions, legal practitioners and accountants subject to certain restrictions (which will be advised by CGI as required).

TRANSACTIONS

Source of funds:

We will require information and verification of the source of funds that will be utilised in or through the structures that we will manage on your behalf.

Destination of funds:

Where relevant, we may require information on persons, corporate or other structures to which funds are paid to from the structures that we will manage on your behalf.

In some instances we may request proof of the bona fides of a transaction to verify its legality.