The directors of IFG are obligated by law and company policy to go through the process of information gathering to evidence that due diligence was applied in making the decision to enter into the business relationship.

The rule is "know your client". Irrespective of the form of the structure that we are requested to form or administer, we are required to determine the identity and establish the bona fides of each prospective new client. Unless the prospective client is a public company, we look through any intermediate ownership structures and seek information on the ultimate beneficial owner. There is no set procedure on how to go about the business of information gathering, as circumstances will differ from client to client.

Generally, the basic information we require is as follows;

• A certified copy of the photograph page of the prospective client's passport or identity card.
• The certifier must be a suitable person, such as a lawyer, an accountant, a director or manager of an authorised credit or financial institution, a notary public, a member of the judiciary, a senior civil servant, a British Embassy official, or a serving Police Officer.
• The certification should be written on the face of the copy document itself rather than on an attachment and should state on the identification document that it is true copy of the original document. The certifier should include his/her signature, name in block capitals, daytime telephone number, profession, name and address of business or official stamp, and date on the document being certified
• A bank or professional reference from persons or organisations that have dealt with or have known the person for a period no less than two years.
• An original (or copy certified as explained above) utility bill, not more than 3 months old, (e.g.; gas, electricity or telephone (not mobile) bill) or bank statement or other official document showing the residential address of the person.
• An explanation of the reason for the establishment and expected activities and purpose of the entity (trust, company, foundation, partnership, etc.) together with an estimate of turnover and transactional activity.
• A confirmation of the source of funds to be injected into the entity (i.e. generated from what transaction or business) and the source of wealth of the beneficial owner of the entity.
• A form of confirmation of the occupation of the beneficial owner.

Where there are intermediate companies between the ultimate beneficial owner and the entity that we are requested to form or manage, we require confirmation that these companies exist, are in good standing and are properly managed, by reference to the Certificate of Incorporation, Memorandum and Articles of Association, (Bye-laws), Certificates of Good Standing and Incumbency, extracts from the appropriate Companies Register, the Annual Report and management accounts.

If the beneficial owner is a public company we require;

• a copy of the Memorandum and Articles of Association;
• a copy of the latest annual report;
• a current listing of directors and officers certified by the company secretary;
• a copy of the board resolution of the parent company authorising the formation of the entity that we shall manage identification documentation as specified above and references where necessary for key directors and any persons authorised to give instructions.

The above information is not intended as a comprehensive guide to IFG due diligence requirements, full details may be obtained from IFG offices upon request.