As I was reminded today when I checked my watch and realised that the numbers seems to have shrunk somewhat, time is passing. And although we are all now so familiar with the basic principles of the AML regime that we could recite them in our sleep (and indeed, according to my husband, some of us do), it is vital that we remember to revisit them from time to time to check that they are still appropriate and proportionate. Someone in a training session last week encouraged me to question something I had been taking for granted when she asked, “About recent utility bills as proof of address – what if the customer does everything online and gets paperless statements? And anyway, what counts as ‘recent’?”
Indeed. So I settled into my wing-back chair to consult my beloved, leather-bound copies of the guidance, and it seems that the humble utility bill still has some status for due diligence purposes. According to the JMLSG here in Blighty, when seeking documentary proof of someone’s address, you can ask for “utility bills (but not ones printed off the internet)”. And a couple of references are made to documents being “recent”, without a definition of that term. Surely it’s all relative – to me, 1987 still seems quite recent (you remember: IKEA came to the UK, and we had a hurricane, although I believe the two events were unrelated). Looking further afield, to Guernsey and Jersey, the guidance in both jurisdictions says that residential address can be evidenced by “a bank statement or utility bill”, although neither island specifies that it has to be recent. The Financial Supervision Commission in the Isle of Man, however, is a bit more prescriptive: as proof of address, you can accept “A recent rates, council tax or utility bill (recent in respect of utility bills is considered to be no more than 6 months old). Utility bills received electronically, rather than by post at the relevant residential address, are not acceptable. Mobile telephone bills are not acceptable as evidence of address under any circumstances.”
Of course we can all see the logic of that last caveat: a “traditional” utility bill (rather than one for a mobile phone) is related to a physical property – and after all, we are collecting information about the customer’s address so that the police know where to go to arrest him. But is it really practical to insist that it has to be delivered by the postie? After all, how many institutions ask for the bill and its envelope, to prove that it came by post? And those who claim that a posted bill is much harder to forge than an e-bill are deluding themselves. It’s not the posted-ness of the utility bill that is useful; it’s the fact that it ties the person to a physical address. (In countries that use PO box addresses extensively, MLROs teach their staff to look for the “service address” on the utility bill, rather than the delivery address.) So perhaps the time has come to look for a more practical and valuable alternative to that utility bill. What could we ask for that would achieve what we need, i.e. proof that someone lives where they say they live?