05.04 – Confirming the Reasonableness of Self Certification

A Financial Institution receiving a self certification must consider other information it has obtained concerning the individual to check whether the self certification is reasonable.

When considering reasonableness the nature of any conflicting information must be considered:

Example

An individual opens a new account, and self certifies as UK tax resident, but the Financial Institution’s AML procedures all relate to an address in Jersey. In a case such as this the Financial Institution may need to make further enquiries to establish whether or not the self certification is reasonable.

Example

An individual opens a new account, and self certifies as UK tax resident but gives Gibraltar as their place of birth. Although the account holder was born in Gibraltar the place of birth does not directly impact on the tax residence of the individual. In a case such as this, if the Financial Institution’s AML procedures do not indicate a residence other than the UK then the Financial Institution may consider that the self certification is reasonable.

Example

An individual opens a new account, and self certifies as UK tax resident, but their passport shows Austrian citizenship. Although the account holder may be an Austrian citizen, this does not directly impact on the tax residence of the individual. In a case such as this, if the Financial Institution’s AML procedures do not indicate a residence other than the UK then the Financial Institution may consider that the self certification is reasonable.