Summary


This article will outline how First AML verify Specified Managing Intermediaries under Australian, New Zealand, and United Kingdom AML legislation. 



Who do we verify?


  1. All beneficial owners with interest >25%.
  2. All effective controllers of the SMI.



What do we verify?


  1. Full name, address and registration number (if applicable) of the SMI.
  2. That the SMI has an AML/CFT programme, is supervised for AML/CFT purposes, completing CDD in accordance with the AML/CFT Act and its principal place of business.
  3. Obtain written confirmation from a senior manager of the SMI to the effect that it: 
    1. has an AML/CFT programme in place (or a foreign equivalent); 
    2. is supervised for AML/CFT purposes;
    3. is doing CDD in accordance with the AML/CFT Act (or its foreign equivalent); and
    4. has its principal place of business in a jurisdiction with sufficient AML/CFT systems and measures in place