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A major part of our work is simply that of 'Due Diligence'.
Charles Stirling International is obligated by law
and company
policy to go through the process of information gathering
to
evidence that due diligence was applied in making the decision
to enter into the business
relationship.
This rule is "Know Your Customer". Irrespective of the form
of the offshore structure or
investment that we are requested to
perform or administer, we are
required to determine the identity
and establish the bona fides of
each prospective new client. This
is also due to further changes to
Common Trading Practice in
respect of the Prevention of Money
Laundering (now known as
the Anti Money Laundering Standards for
Insurance Business).
Unless the prospective
client is a public company, we look through
any intermediate ownership
structures and seek information on the
ultimate beneficial owner.
There is no set procedure on how to go
about the business of
information gathering, as circumstances will
differ from client to
client.
Generally, the basic information we require is as follows:
- A certified copy of the photograph page of the
prospective client's passport or identity card.
- The certifier must be a suitable person, such
as a lawyer, an accountant, a director or manager of an authorised
credit or financial institution, a notary public, a member of the
judiciary, a senior civil servant, a British Embassy official, or a
serving Police Officer.
- The certification should be written on the face
of the copy document itself rather than on an attachment and should
state on the identification document that it is true copy of the
original document. The certifier should include his/her signature, name
in block capitals, daytime telephone number, profession, name and
address of business or official stamp, and date on the document being
certified
- A bank or professional reference from persons
or organisations that have dealt with or have known the person for a
period no less than two years.
- An original (or copy certified as explained
above) utility bill, not more than 3 months old, [e.g.; gas, electricity
or telephone (not mobile) bill] or bank statement or other official
document showing the residential address of the person.
- An explanation of the reason for the
establishment and expected activities and purpose of the entity (trust,
company, foundation, partnership, etc.) together with an estimate of
turnover and transactional activity.
- A confirmation of the source of funds to be
injected into the investment or entity (i.e. generated from what
transaction or business) and the source of wealth of the beneficial
owner of the entity.
- A form of confirmation of the occupation of the beneficial owner.
If the beneficial owner is a public company we require copies of:
- The Memorandum and Articles of Association
- The latest annual report.
- Current listing of directors and officers
certified by the company secretary.
- The board resolution of the parent company authorising the formation
of the entity that we shall manage identification documentation as specified
above and references where necessary for key directors and any persons
authorised to give instructions.
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