CDD: Documents Required for Verification by RE

Not only the responsibility for getting the documents, but also verifying authenticity and accuracy and furnishing details to FIU-Ind as prescribed,  is on the REs.

1. Individuals

 

SL NO	Person	Verification	Documents(Certified Copy)
1	Individual	Identity & Address	Passport/ driving licence/ Permanent Account Number (PAN) Card/ Voter's Identity Card issued by the Election Commission of India/ identity card with applicant’s Photograph issued by Central/State Government Departments, Statutory/Regulatory Authorities, Public Sector Undertakings, Scheduled Commercial Banks, and Public Financial Institutions/ ) letter issued by a gazetted officer, with a duly attested photograph of the person
			One recent photograph
			Such other documents including the ones related to the nature of business and financial status of the client, as may be required by the banking company or the financial institution or the intermediary

2. Company

SL NO	Person	Verification	Documents(Certified Copy)
2	Company	Name, business, principal place of business of company and details of power of attorney holders	Certificate of incorporation; Memorandum and Articles of Association
			A resolution from the Board of Directors and power of attorney granted to its managers, officers or employees to transact on its behalf
			An officially valid document in respect of managers, officers or employees holding an attorney to transact on its behalf
			Due diligence documentation has now [March 2023]expanded beyond just getting the fundamental KYCs of clients, such as registration certificates, PAN copies, and documents of officers with the authority to act on their behalf. Depending on the legal structure of the firm, it now also involves the submission of information, such as the names of those in top management positions, partners, beneficiaries, trustees, settlors, and writers. Moreover, clients must now provide information about their registered office and primary place of business to financial institutions, banks, or intermediaries.

3. Partnership Firm

SL NO	Person	Verification	Documents(Certified Copy)
3	Partnership Firm	Name, business, principal place of business of firm and details of power of attorney holders	Registration certificate Partnership deed
			An officially valid document in respect of the person holding an attorney to transact on its behalf
			Due diligence documentation has now [March 2023]expanded beyond just getting the fundamental KYCs of clients, such as registration certificates, PAN copies, and documents of officers with the authority to act on their behalf. Depending on the legal structure of the firm, it now also involves the submission of information, such as the names of those in top management positions, partners, beneficiaries, trustees, settlors, and writers. Moreover, clients must now provide information about their registered office and primary place of business to financial institutions, banks, or intermediaries.

4. Trust

SL NO	Person	Verification	Documents(Certified Copy)
4	Trust	Identity, address and details of power of attorney holders	Registration certificate; Trust deed
			An officially valid document in respect of the person holding an attorney to transact on its behalf
			Due diligence documentation has now [March 2023]expanded beyond just getting the fundamental KYCs of clients, such as registration certificates, PAN copies, and documents of officers with the authority to act on their behalf. Depending on the legal structure of the firm, it now also involves the submission of information, such as the names of those in top management positions, partners, beneficiaries, trustees, settlors, and writers. Moreover, clients must now provide information about their registered office and primary place of business to financial institutions, banks, or intermediaries. Where the client is a trust, a reporting entity will be required to ensure that trustees disclose their status at the time of commencement of an account-based relationship or when carrying out any transaction of an amount equal to or exceeding ₹50,000 , whether conducted as a single transaction or several transactions that appear to be connected or any international money transfer operations.

5. Association of Persons / Body of Individuals

SL NO	Person	Verification	Documents(Certified Copy)
5	Association of Persons (AOP) or Body of Individuals(BOI)		Power of attorney granted to (the authorized person) to transact on its behalf;
			An officially valid document in respect of the person holding an attorney to transact on its behalf
			Such information as may be required by the banking company or the financial institution or the intermediary to collectively establish the legal existence of such an association or a body of individual

Every reporting entity should exercise ongoing due diligence with respect to the business relationship with every client and closely examine the transactions in order to ensure that they are consistent with their knowledge of the client, his business and risk profile and where necessary, the source of funds.

Happy Reading

Those who read this, also read:

1. Customer Due Diligence

2. Beneficial Owner

3. Customer due Diligence(CDD)- Individuals

4. The Know Your Customer (K Y C) Policy 

5. RBI Guidelines on AML/CFT and PMLA 2002

6. RBI Guidelines on Transaction Analysis