Anti-money laundering requirements

Product Type

Protection products

  • Customer due diligence requirements (photo ID and address verification) will be deferred until claim stage
  • PEP question and PEP questionnaire are still required at new business stage
  • If being paid by someone other than the policy owner, it will be necessary to confirm the nature of the relationship between the policyowner, the life assured (if different to the policy-owner) and the and 3rd party payer
Product Type

Regular savings plans and top-ups

Investment policies and top-ups

  • Establish Source of Funds/Source of Wealth
  • Customer due diligence requirements will apply at new business stage and in all cases, irrespective of the amount being invested.
  • If being paid by someone other than the policy owner, it will be necessary to confirm the nature of the relationship between the policyowner, the life assured (if different to the policy-owner) and the third party payer. Customer due diligence will also apply to the third party.
Product Type

Pensions

  • Exempt

Documentary evidence for photo ID and address verification: individuals

One item from the list of photographic ID documents and one item from the list of non-photo identification documents (for address verification) are required for customer due diligence.

Business should be preferably conducted “face-to face” with the customer in order to examine the authenticity of the original documents. Photocopies of originals may be submitted to Irish Life but must be clear and legible and certified by a solicitor, garda, bank official, the regulated financial advisor or an Irish Life employee. Photocopies should be marked “original sighted” and signed/dated by the one of the above to evidence this has occurred.

Photo ID

  • Current passport (Irish or international)
  • Current driving licence (with photo)

Non-photo ID

First choice is a current utility bill but if that it is not possible an alternative is acceptable

**When proof of address is printed from the internet, the document must clearly show the service provider’s name and appear authentic. A bank statement printed from the internet must clearly have the bank name, account sort code and number printed on it. Transaction printouts are not accepted.

Current” means a specific expiry date has not passed. In the absence of a specific expiry, the date of the document must be no older than six months at time of its submission.

  • Utility bill (including those printed from the internet)**
  • Current local authority document e.g. refuse collection bill, water charge bill (including those printed from the internet)**
  • Current bank statements or credit/debit card statements, issued by a regulated financial sector designated person in the Ireland, EU or comparable jurisdiction (including those printed from the internet)**
  • Current documentation/cards issued by the Revenue Commissioners showing the name and address of the person and their PPSN
  • Current documentation/cards issued by the Department of Social and Family Affairs showing the name and the address of the person and PPSN
  • Instrument of a court appointment (such as liquidator, or grant of probate)
  • Current household/motor insurance certificate and renewal notice
  • Medical card for over 18s with intellectual disability

Due diligence requirements for business entities

Listed entity (listed on a recognised stock exchange or a subsidiary of such a company

  • A letter from the company on headed paper with authorisation for nominated individuals to act on the behalf of the company

Unlisted entity or private company

  • A letter from the company on headed paper with authorisation for nominated individuals to act on the behalf of the company
  • Names of the directors; and
  • Names of beneficial owners with greater than 25% of the shares or voting rights or who otherwise exercise control
  • Full name
  • Registered number
  • Registered office address in country of incorporation; and
  • Principal business address

The identity of the entity should be established by obtaining:

  • Copy of the company’s Certificate of Incorporation
  • Photo ID and address verification for two directors and all beneficial owners with a 25% or greater shareholding