Summary


As part of all new case requests, First AML will complete a database scan before contacting the client with an information request. This scan covers our whole ecosystem to check whether we already hold any information on file for the client. 


Where there is existing valid information within the database, we will seek consent to reuse all possible relevant information and confirm if there have been any changes to the beneficial ownership structure (if not publicly available).


Any documentation that has expired or materially changed will be collected and updated for your records e.g. certified documents that have expired. 


All individuals requiring identity verification will be contacted to confirm they consent to such, and name, date of birth and address verification will be re-performed along with PEP checks.


Due to privacy reasons, if there is a close match (but not an exact match i.e. no confirmation of middle name), First AML will not start with a retrieval request. We will instead ask the Customer to confirm if they have previously been verified by First AML and to confirm the entity/individuals names.