Our philosophy is that any successful business relationship must be based on mutual trust, openness and understanding.
True Story - Back in the 1990's, our senior partner was working for a certain bank in an offshore jurisdiction. The account in question had a rather large balance, Suddenly there were 3 people each claiming to be the beneficial owner and wanting "his / her" money to be transferred elsewhere. But which was the real owner? The staff who originally interviewed the 'new client' was no longer with the bank to identify the owner and there was insufficient documentary evidence to prove the actual owner. This served as a sharp "wake-up" call to the bank, which dramatically increased its due diligence. Do you want to risk someone claiming your assets?
For the protection of all our stakeholders, we have strict policies in place to prevent our services being abused for illegal purposes such as money laundering or the financing of terrorism. We balance this with a keen understanding of the realities of doing business in different parts of the world. Group members have therefore implemented a risk-based approach to Customer Acceptance policies. Together, this forms our “Know Your Client” or KYC procedure.
We do not do business anonymously. Our over-riding intention and obligation is to develop and document a clear picture of who we are dealing with, where they live, what their business is and what is their source of wealth. In some cases this will be obvious and easy to establish for both ourselves and the client, while in some cases it will be more complex. We do understand cultural differences in Asia when compared to North American or European standards. Documents are only one part of this process, albeit an important part especially in non face-to-face transactions. In general clients should expect to send us the following documentation:
PROOF OF IDENTITY – The preferred document is an internationally-valid passport. If the client does not have a passport, other documents may be accepted depending on the jurisdiction of issue. For example we may accept internal passports of the Russian Federation, national or state IDs or drivers licenses issued within the US, Canada and the European Union, or any other government-issued document where the compliance officer is confident that the document is valid and accurately identifies the subject.
PROOF OF ADDRESS – This must be proven by documents such as utility bills, bank or credit card statements, recent certificate of residence issued by a government authority etc, or a check of public records.
EXPLANATION OF SOURCE OF WEALTH AND FUNDS AND PURPOSE OF STRUCTURE – This will be subject to review by a qualified compliance officer with experience of business realities in the geographic region of the client, who may verify information against third party databases, or ask additional questions if he or she is not immediately able to develop a clear understanding of the client’s business activities.
People and businesses change with time and we also have an ongoing responsibility to continue to understand our clients’ businesses. This continued mutual understanding and trust makes business run more smoothly and prevents costly and inconvenient misunderstandings.
If you have any questions about our KYC or Due Diligence procedures, please contact your Consultant who will be pleased to assist you.