Identity verification certificates
The identity verification certificate (IVC) is part of the application form and must be signed by an authorised person in your firm who has seen the original documentation. There must be separate evidence to verify your client’s identity and address. A separate IVC must be completed for the applicant and anyone else who pays contributions into the SIPP. Where there is third party involvement - for example, the employer is making contributions as well - you should also identify that person or entity.

Source of wealth and funds
It is important to identify the source of funds to comply with guidance surrounding anti money laundering legislation. The source of funds will often be "transfer from another pension scheme", and source of wealth is typically "funded from employment" or "inheritance" or "bonus payment" etc.

Should you have any concerns over the source of the funds in question, you should follow your own standard anti money laundering procedure and you should not report your concerns personally to any member of staff at Suffolk Life. You should also not introduce the client to Suffolk Life unless your firm is satisfied that your concerns have been answered.

Certifying of documents
If photocopies of documentary evidence are attached, the person from your firm signing section 2 of the application form must certify them. Each photocopy must be individually certified with an original signature. Further certification of previously certified copies by the firm is acceptable provided the previous generation document bearing an original certification has been seen by the firm.

The certification should read ‘Certified as a true copy of the original document (and that the photograph is a true likeness of the individual seen at the same time as the original document)’. The person certifying the copy should sign it, enter their name, qualification (if applicable), business name, business address, position in business, FSA register number (if applicable) and date.

If you don’t see your client face to face, they may wish to supply you with certified copies of the evidence. This is acceptable provided that the person certifying the documents works for a firm authorised by the FSA or is a qualified professional (e.g. accountant or solicitor). Your client cannot certify their own documents.

Evidence of identity
Evidence of your client’s identity obtained in the past may be acceptable provided it is still current, for example an unexpired passport or driving licence. Older documents evidencing your client’s address will be acceptable provided the address on the evidence matches that on the application form.

For non-UK nationals, certified copies of equivalent documentary evidence may be submitted. A lawyer, attorney, embassy official, consulate or high commissioner of the country of issue must certify passports, identity cards and documentary evidence of address for non-UK nationals. You can re-certify copy documentation, provided that one of the people mentioned above has originally certified it.

Evidence of address
If you’re using the electoral roll as evidence you must send a certified copy of your search. If a solicitor’s letter confirming house purchase is used for address verification, you must send a certified copy of the letter along with evidence confirming the previous address. Home visits can be used as evidence of address only when the person completing and signing the certificate has entered the premises. For self-employed persons in the construction industry a tax exemption certificate with photograph is acceptable evidence.

Age of the evidence
Normally, evidence must be recent when you see the documents. As a guide:

• bank statement – within 1 month
• mortgage statement - within 1 year
• credit card statement – within 1 month

Unacceptable evidence
The following are some of documents that are not acceptable

• mobile telephone bills
• old-style (non-photo) provisional driving licences
• expired passports or driving licences

Company or non-individual identity verification
When contributions are being made from a company or other non-individual, you must verify their identity before any contributions can be accepted. You need to provide the appropriate identity verification certificate for a non-individual, is available by clicking here. Alternatively, the following can be used as a guide.

For companies we need:

• full name
• registered number
• registered office in country of incorporation
• business address

We will verify the information supplied by

• a search of companies house register, or
• confirming that the company is listed on a regulated market, or
• obtaining a copy of the certificate of incorporation

For private companies we will also need

• names of all directors, and
• names of beneficial owners holding over 25% of the company

For partnerships and unincorporated companies we need

• full name of the organisation
• registered address
• business address
• establishment document (where applicable)
• names of beneficial owners holding over 25% of the company

For trusts, instead of the standard information, we need

• full name of the trust
• nature and purpose of the trust
• country of establishment
• name of all trustees
• name and address of any settlor or controller