How do I verify the identity of a client without standard documentation?

I am a money laundering reporting officer (MLRO). Fee earners sometimes ask how to verify clients – such as immigration clients – who are unable to produce standard identity documentation. How can we verify these clients’ identities?

Sometimes clients are unable to provide standard verification documents.

The purpose of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 is not to deny people access to legal services for legitimate transactions but to mitigate the risk of legal services being used for the purposes of money laundering.

You should consider whether the inability to provide you with standard verification is consistent with the client’s profile and circumstances or whether it might make you suspicious that money laundering or terrorist financing is occurring.

Where you decide that a client has a good reason for not meeting the standard verification requirements, you may accept a letter from an appropriate person who knows the individual and can verify the client’s identity.

For example:

  • a refugee might be able to provide:
    • a letter from the Home Office confirming refugee status and granting permission to work, or
    • a Home Office travel document for refugees
  • an asylum seeker might be able to provide:
    • their registration card and any other identity documentation they hold, or
    • a letter of assurance as to identity from a community member such as a priest, GP or local councillor who has knowledge of the client

For more information, see chapter 6 of the anti-money laundering guidance for the legal sector.


While every effort has been made to ensure the accuracy of the information in this article, it does not constitute legal advice and cannot be relied upon as such. The Law Society does not accept any responsibility for liabilities arising as a result of reliance upon the information given.

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