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 customer’s Document Library 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).
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 the 5th AML Directive (AMLD5)?
The 5th Anti-Money Laundering Directive (AMLD5) was published in 2018 and amended the 4th AML Directive. The amendments introduced by the 5th AML Directive represented a substantial improvement to prevent the EU financial system from being used for money laundering and for funding terrorist activities. More information is
on the FCA website.
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.
You've not asked for this data previously, why now?
The introduction of the 4th and 5th EU Anti-Money Laundering Directives and increased focus on AML policies post the Russia/Ukraine conflict means that we need to ensure that abrdn and the firms we do business with are meeting regulations. Our ultimate goal is to ensure customer money is as safe as possible. All advisers and providers must identify and, where appropriate, verify 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.
As an illustration of the increased regulatory focus and standards expected, the FCA conducted a recent review of financial crime controls at challenger banks following a risk assessment which identified a risk that information gathered at the account opening stage was insufficient to able to identify high risk customers:
One key point to note from their summary is:
“We found weaknesses in CDD. For example, most challenger banks did not obtain details about customer income and occupation, resulting in an incomplete assessment of the purpose and intended nature of a customer’s relationship with the bank.”
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?
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 (Wrap and Elevate only) at the same time as the signed customer terms and conditions or sent to us in the post (Wrap, Elevate and Fundzone).
Why isn't the information being collected on the platform?
We plan to be able to capture all of the required information on our platforms in the future. We can capture a customer’s Nationality on our platforms currently, however, as we also need to know about Dual Nationality (if applicable), Occupation, Industry, Source of Funds and Source of Wealth, the AML Compliance Form is designed to capture all of this information and allows abrdn to meet its regulatory requirements while we design an on-platform solution. We would encourage you to add your customers’ Nationality directly onto the platform as well.
Who needs to sign the AML Compliance Form?
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.
Whose information should be captured on the AML Compliance Form for a JISA?
The form should be completed with the account holder’s data, not the child’s.
When is this effective from?
Individual/Joint accounts: the new process and AML Compliance Form came into effect on 15 September 2022.
Trust/Corporate accounts – the new process and updated Beneficial Owner Forms came into effect on 1 September 2022 in order to comply with the Trust Registration Service (TRS) regulation.
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 abrdn’s 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 AMLD5, certain trusts need to be registered before abrdn 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.
Is the CRBOT (Irish Registration for Offshore Bond Trusts) required from October?
No; following guidance from the Irish Revenue, the CRBOT is currently suspended until further notice.I have a case in progress what is the cut off date for sending the form
For Trust and Corporate – if the Wrap account is submitted but we’ve not received any paperwork then we won’t need the new form. For Individual and Joint – the new form must be received for all cases submitted from 15 September 2022.Where can I find a copy of the forms?
Copies of the forms are held on the platform literature library as well as the Wrap help section of this website.Do I need to send any supporting evidence in with the AML Compliance Form?
No; we don’t need any further information or evidence.I have more questions; who can I contact to find out more?
Please speak to your usual abrdn 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.