Forms to submit before we can activate an account
We need to capture additional information at customer sign-up before activating customer and trust/corporate accounts. This is to make sure we keep you and your clients compliant with 5th EU AML Directive and fulfil our AML and CTF regulatory obligations.
Download the appropriate form from the lists below. Once completed, the form should then be uploaded to the Request Centre at the same time as the Customer Terms & Conditions (Wrap and Elevate only) or sent to us in the post (Wrap, Elevate and Fundzone). Once received we will activate the account(s). To begin, select “New client sign‑up” in the Request Centre. You can read more about the Request Centre.
If we don’t receive the form, the customer account will not be activated.
Individual and Joint accounts
Trusts and Corporate Accounts
We need you to complete more detail than was previous required in the Beneficial Ownership form. Please view the forms below and our operational process for the Trust Registration Service.
Q &A
What is Customer Due Diligence (CDD)?
CDD is undertaken as part of Anti-Money Laundering Policy and procedures. CDD consists of identifying and, where appropriate, verifying the identity of the Customer and any relevant Related Parties such as beneficial owners and controllers and secondly, gathering and recording information in relation to the nature of business and expected account activity to assist in identifying unusual (potentially suspicious) transactions/activity.
Why are you asking for this extra detail?
We have to comply with Anti-Money Laundering regulations – this includes maintaining up to date beneficial owner records for your Wrap, Elevate and/or Fundzone clients (the ‘investing entity’). There is greater focus on Anti-Money Laundering regulation globally to try and combat money laundering and terrorist financing. More information is on the FCA website.
What information do you need?
For new individual customers and individuals related to Trusts/Corporate accounts, the following additional customer data will be required at the point of on-boarding to any of our platforms:
- Their Nationality (including whether they have Dual Nationality) – this is already a field on our platforms but it is not compulsory which is why we need to ask for it on this new form.
- Their Occupation and associated Industry.
- The Source of Funds (SoF) – this is where the money invested in this product has come from. For example, it could be savings they have accumulated from a fixed portion of their employment income every month for investment purposes and/or inherited wealth. It is not the bank account where the money has come from.
- The Source of Wealth (SoW) – Source of Wealth is different to Source of Funds as it is where all your customer's accumulated wealth across all of their products have come from. For example, Source of Funds could be accumulated from employment income on your customer's ISA but Source of Wealth could be accumulated from employment income, inheritance and the sale of a business across multiple products. In some cases SoW and SoF could be identical.
Which customers do you need this information for?
We need this information for all new platform customers: for Individual, Joint, Corporate and Trust accounts.
How will you gather this information?
For Wrap, this information will be captured on the platform directly. For Elevate, this additional information will be captured via a new AML Compliance Form which needs to be completed by the adviser and uploaded to the customer’s Document Library (Elevate only) at the same time as the signed customer terms and conditions or sent to us in the post (Elevate).
Who needs to sign the AML Compliance Form for Elevate?
The form does not need to be signed.
I've sent an AML Compliance Form in previously, do I need to send another one in?
All new accounts will need to have a new form; this is because the information must be correct at the time of account opening.
I'm setting up a Joint Account, how many CDD forms do I need to complete?
You will need to complete a form for each customer; so, for joint cases we will need two forms.
Who should the AML Compliance Form be completed for with POA and Court of Protection order cases?
The form should be completed for the individual customer and should be sent in along with legal proof of the Power of Attorney.
Can we accept another version of the form, e.g. an adviser's own or another provider's?
Whilst the questions may be similar, we need to ensure the answers can be mapped on to the drop down lists we have specified in our form. Therefore, we would not be able to accept any other third-party forms.
What will you do with the information once I give it to you?
The information will be stored securely in the customer Document Library/on our compliance systems.
What do you mean by Source of Funds?
Source of Funds is where the money invested in this product has come from. For example, it could be savings they have accumulated from a fixed portion of their employment income every month for investment purposes and/or inherited Wealth. It is not the bank account where the money has come from. In some cases, the SoW and SoF could be identical.
What do you mean by Source of Wealth?
Source of Wealth is different to Source of Funds as it is where all your customer's accumulated wealth across all of their products have come from. For example, Source of Funds could be accumulated from employment income on your customer's ISA but Source of Wealth could be accumulated from employment income, inheritance and the sale of a business across multiple products. In some cases, the SoW and SoF could be identical.
What is the Trust Registration Service (TRS)?
As per UK regulations certain trusts need to be registered before we can accept new business. Visit gov.uk for details of Trusts that need to be registered.
Do you need to see TRS details for new customers?
Yes, we must see proof in the form of the PDF excerpt which can be printed/downloaded from the register. View here for more details.
Do you need to see TRS details for existing customers?
From 01/04/23, HMRC extended legislation to cover ongoing relationships. View here for more details.
What is CRBOT? (Irish Registration for Offshore Bond Trusts)
Due to EU anti-money laundering rules, all trusts with a Standard Life International Portfolio Bond on Wrap must register with CRBOT, even if already registered with the UK TRS.
You can register here Non Resident Trust Register.
Where can I find a copy of the forms?
Copies of the forms are held on the platform literature section as well as the Elevate and Wrap help websites.Do I need to send any supporting evidence in with the AML Compliance Form?
No; should we require further information or evidence we will contact you directly.I have more questions; who can I contact to find out more?
Please speak to your usual Aberdeen contact or call us on:Wrap: 0345 279 1001 lines are open 9am to 5.30pm, Monday to Friday.
Fundzone: 0345 279 2002 lines are open 9am to 5pm, Monday to Friday.
Elevate: 0345 600 2399 lines are open 9am to 5pm, Monday to Friday.
As part of our commitment to quality service and security, telephone calls may be recorded. Call charges will vary.
