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