Summary


This article will outline how First AML verify partnerships under Australian, New Zealand, and United Kingdom AML legislation. This article will cover informal, formal, and limited partnerships. Please use the table of contents to skip to the relevant section. 


*ID&V = Identity Verification (Identify & Verify)




TABLE OF CONTENTS




Informal Partnership (NZ + UK*)


*Not applicable for Australia


Who do we verify?

  1. Only ID&V Partners with over 25% Beneficial interest
  2. If the partner is non-individual must ID&V per relevant entity type.
  3. Only ID&V Beneficiaries if they are non-discretionary
  4. ID&V all ownership interest >25%. If no beneficial ownership > 25%, nominate 1 individual. 

What do we verify?

  1. Name, address, registration number (if applicable) of the Partnership
  2. Signed version of the Partnership agreement and any amendment deeds; or 
  3. Confirmation from solicitor or accountant confirming  all partners + their Shareholding %
  4. Where there is no partnership agreement, obtain a written confirmation from the customer or the firm to confirm the informal partnership & it’s partners & % of shareholdings each partner holds.



Formal Partnership (NZ + UK*)


*Not applicable for Australia


Who do we verify?

  1. Only ID&V Partners with over 25% Beneficial interest
  2. If the partner is non-individual must ID&V per relevant entity type.
  3. Only ID&V Beneficiaries if they are non-discretionary (and own > 25%
  4. ID&V all ownership interest >25%. If no beneficial ownership > 25%, nominate 1 individual


What do we verify?

  1. Signed version of the Partnership agreement and any amendment deeds; or 
  2. Confirmation from solicitor or accountant confirming  all partners + their Shareholding %. - Can’t accept from partner(s) directly.
  3. Name, address, registration number (if applicable) of the Partnership




Limited Partnership (NZ + UK)


Who do we verify?

  1. ID&V all beneficial owners holding >25%.
  2. Non-Individual: ID&V shareholders/beneficial owners of that entity & go back until natural persons reached or holding until <25%
  3. Must confirm whether there are any nominee general partners or limited partners
  4. We do not verify the directors of a limited partner company. 
  5. We do not verify the shareholders of a general partner company.
  6. If there is a nominee LP, must verify the identity of both the nominee and the ultimate beneficial owner.
  7. Nominees must confirm in writing who they are holding the shares on behalf of or provide a deed of nomination to support their statement.

What do we verify?

  1. Registration extract
  2. Signed Limited Partnership Agreement and any amendment deeds; or confirmation from their lawyer/accountant
  3. Name, registered office address, country of incorporation & registration # (if applicable).




Limited Partnership (AUS)


Who do we verify?

  1. ID&V all beneficial owners holding 25% or more
  2. Non-Individual: Must ID&V shareholders/beneficial owners of that entity & go back until natural persons reached or holding until <25%
  3. ID&V any other individuals/entities with effective control i.e. 'managers'
  4. Must confirm whether there are any nominee general partners or limited partners
  5. First AML will verify the shareholders of a general partner company.
  6. If there is a nominee LP, must verify the identity of both the nominee and the ultimate beneficial owner.
  7. Nominees must confirm in writing who they are holding the shares on behalf of or provide a deed of nomination to support their statement.


What do we verify?

  1. Certified Registration extract
  2. Certified Signed Limited Partnership Agreement and any amendment deeds; or confirmation from their lawyer/accountant
  3. Name, registered office address, & registration # (if applicable).