KYC/AML Client Onboarding Checklist

Free KYC/AML Client Onboarding Checklist (UK)

Use this free template as a starting point for client onboarding under the UK Money Laundering Regulations 2017 (as amended). Designed for regulated firms (accountants, solicitors, financial advisers, estate agents, trust and company service providers, and others within scope) to evidence customer due diligence (CDD) for each new client. Copy and customise it to suit your sector, risk appetite, and your firm's policies.

KYC / AML CLIENT ONBOARDING CHECKLIST (UK)

Client name: [Full legal name of client] Client type: [Individual / Sole trader / Partnership / Limited company / LLP / Trust / Charity / Other] Date of onboarding: [Date] Engaging fee earner / partner: [Name] MLRO / Compliance reviewer: [Name] File reference: [Internal reference]

Regulatory Background

This checklist supports compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the "MLRs"), including:

• Regulation 27 (Customer Due Diligence requirements)
• Regulation 28 (CDD measures)
• Regulation 33 (Enhanced Due Diligence in high-risk situations)
• Regulation 35 (PEPs and family members / known close associates)
• Regulation 40 (Record-keeping obligations)

It is also informed by the JMLSG guidance and, for relevant sectors, the [SRA Sectoral Risk Assessment / ICAEW guidance / FCA Financial Crime Guide / other].

The checklist is not legal advice. Each regulated firm must apply its own AML policy, controls, and risk-based approach.

1. Client Identification (Reg. 28(2))

For individual clients:

• Full name (as on government-issued ID)
• Date of birth
• Residential address (current, with proof not older than 3 months)
• Nationality
• Passport / National ID / UK driving licence (copy obtained and verified)
• National Insurance number / Tax ID (where applicable)

For corporate / legal entity clients:

• Full legal name
• Country of incorporation and registration number
• Registered office address
• Business address (if different from registered office)
• Nature of business and main activities
• Company structure chart
• Names of directors and senior management
• Names of beneficial owners (≥25% ownership or control)
• Companies House extract or equivalent (current within [3 months])
• Articles of association / constitutional documents

For trusts, foundations, and similar arrangements:

• Trust deed / foundation charter
• Names and addresses of settlor(s)
• Names and addresses of trustees
• Names and addresses of protectors (if any)
• Class of beneficiaries / named beneficiaries with ≥25% interest
• Source of funds and source of trust assets

2. Verification of Identity (Reg. 28(2)(a))

ID verification method used (select one):

• In-person inspection of original documents, with copies retained
• Certified copies from a regulated person
• Electronic ID verification (provider: [Name], reference: [Ref])
• Open Banking-based identity check
• Other

Verification outcome: Pass Refer to MLRO Fail Date of verification: [Date]

3. Beneficial Ownership (Reg. 28(4))

For corporate/legal entity and trust clients, identify and verify all persons with ≥25% ownership or control:

If no person holds ≥25%, identify the senior managing official(s) controlling the entity.

4. PEP and Sanctions Screening (Reg. 35)

• Politically Exposed Persons (PEP) check completed for client and all beneficial owners
  • Result: No match PEP / family / close associate (EDD required)
• UK / EU / UN / OFSI / OFAC sanctions screening completed
  • Result: No match Possible match (escalate to MLRO before proceeding)
• Screening provider used: [Name]
• Date of screening: [Date]

5. Source of Funds and Source of Wealth

• Expected source of funds for this engagement: [Description, e.g. salary, business income, sale of property, investment returns]
• Source of wealth (overall): [Description]
• Supporting documentation obtained:
  • Recent bank statements
  • Payslips / employment confirmation
  • Audited accounts / management accounts (for entity clients)
  • Property sale completion statement (where applicable)
  • Other: [specify]

6. Risk Assessment

Overall client risk rating: Low Medium High

7. Enhanced Due Diligence (Reg. 33)

EDD applies if any of: high-risk third country involvement, PEP, complex/unusually large transactions, ownership structure with no apparent economic rationale, or otherwise high risk per firm policy.

If EDD applies:

• Additional verification evidence obtained
• Source of funds and source of wealth verified, not just stated
• Senior management approval to onboard obtained (signature/date below)
• Enhanced ongoing monitoring put in place
• EDD review note prepared and saved to file

8. Purpose and Nature of the Business Relationship

• Purpose of the relationship: [Brief description, e.g. tax advisory services, conveyancing for property purchase, investment management]
• Expected nature of activity and transaction profile: [Description]
• Initial engagement scope: [Reference to engagement letter, dated [Date]]

9. Ongoing Monitoring (Reg. 28(11))

• Trigger events for review: [material change in client circumstances, new beneficial owner, unusual transactions, periodic review dates]
• Periodic review frequency: [Annual for Low risk / Semi-annual for Medium / Quarterly for High]
• Next scheduled review: [Date]

10. Sign-Off

11. Record-Keeping (Reg. 40)

Records, including this checklist and supporting evidence, must be retained for at least 5 years from the end of the business relationship or transaction.

Records held: [File location, document management system reference] Retention review date: [Date 5 years after relationship ends]

This is a basic template provided for informational purposes. For a professionally generated and legally tailored document, use Bind's contract automation platform.