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ID and Proof of Address (POA) Verification Guide

4–6 minutes
ID & POA Verification Guide

Helping you meet your responsibilities under UK AML regulations

Why ID and POA Verification Matters

Under UK Money Laundering Regulations, verifying your clients’ identity is a legal requirement. Whether you are onboarding a new customer or reviewing an existing one, strong verification procedures protect your business and reduce the risk of financial crime.

This practical guide from Flex AML outlines user-friendly steps for verifying identity documents, checking sanctions and politically exposed persons (PEPs), and minimising AML risk. It is written in a clear and approachable tone to support your everyday compliance needs.

Acceptable ID Documents

Accepted photo identification includes:

  • Valid passport (UK or international)
  • UK photocard driving licence (full or provisional)
  • National identity card (for EEA or Swiss nationals)
  • UK residence permit or biometric residence card
  • Firearms licence (photo card issued by a UK police force)

These documents must:

  • Be in date (ideally with 6 months remaining on a passport)
  • Be original and unaltered
  • Clearly show the full name of the customer

💡 Flex Tip: Provisional driving licences are more frequently found to be fraudulent. To minimise risk:

  • Cross-check the licence number via the DVLA website
  • Request a second form of ID
  • Escalate any doubts to management

Best Practice for Manual ID Checks

  • Capture both sides of the document
  • Ensure all four corners are visible in the image
  • Observe ear shape and natural shadows
  • Check for printing anomalies or spelling errors
  • Compare the signature on the document to a live one
  • Authentic documents tend to have a high-quality finish

🚩 Red flag: Mismatched shadows in photocopies may indicate document tampering

Acceptable POA Documents

These should clearly show the customer’s full name and residential address. Most documents must be dated within the last three months:

  • Bank or building society statement
  • Credit card statement
  • Utility bill (gas, electric, water)
  • Council tax bill (current tax year)
  • HMRC letters
  • Tenancy agreement or mortgage statement
  • TV licence letter
  • Letter from a government department or local authority
  • Driving licence (only if not used as photo ID)

Not accepted:

  • Mobile phone bills
  • Handwritten documents
  • Screenshots or edited files
  • Documents over 3 months old (unless clearly stated)

💡 Flex Tip: Credit card and online-only banking statements carry a higher fraud risk. Use extra care.

What to Check on a POA Document

  • Name and address: Must match client records
  • Date of issue: Must be within the required timeframe
  • Document originality: Prefer PDFs or official paper, not screenshots
  • Layout: Consistent formatting, logos, and print quality
  • Tampering indicators: Overwritten text, spacing issues, blurred areas

💡 Flex Tip: Run the address through the Royal Mail postcode checker to confirm it exists: Royal Mail Address Finder

In-Person Verification

If the client is present:

  • Driving licence: Ask the client to log in to the DVLA website and provide you with a check code
  • Passport: Use GOV.UK’s identity verification service

Using Digital Tools

Verification software such as LexisNexis, SumSub or many others can confirm:

  • Full name and date of birth
  • Address history and property ownership
  • Associated individuals
  • Credit history
  • Sanctions and PEP status

These tools also help create a risk score to support escalation or Enhanced Due Diligence (EDD).

Sanctions and PEP Screening

It is mandatory for regulated businesses to:

  • Check all clients against the UK sanctions list
  • Immediately report matches to OFSI
  • Screen for PEPs and apply EDD where relevant

📣 Letting Agents: From May 2025, you must screen all landlords and tenants for sanctions, regardless of rental value. This is now part of standard Customer Due Diligence (CDD).

Use software with automated screening and subscribe to OFSI updates.

Companies House Identity Verification

From 2025, Companies House will begin verifying some company directors. While helpful, this is not a substitute for full AML checks.

Open Source Checks

Apply open source checks to:

  • All individuals linked to the account
  • Shareholders, PSCs, and linked companies

Search tips:

  • Name + address + key terms (“fraud”, “scam”, “arrest”) we have another guide on how to do this!
  • Use forums, review platforms and business directories
  • Verify regulated claims using official registers (FCA, HMRC, Law Society, etc.)

Red Flags to Watch

  • Sanctions or PEP matches
  • Fake documents or addresses
  • Multiple company appointments with no activity
  • Adverse media
  • Complex ownership structures
  • Nervous or evasive behaviour

Record findings, review files annually, and escalate anything unusual.

Enhanced Due Diligence (EDD)

EDD is required for high-risk clients such as:

  • Politically exposed persons
  • Overseas customers
  • Complex corporate structures
  • High-risk industries
  • Adverse media or sanctions matches

EDD may involve:

  • Additional ID or address verification
  • Independent source corroboration
  • Selfie or live video
  • Senior management approval
  • Ongoing transaction monitoring

💡 Flex Tip: Send a postal verification code to confirm a residential address.

Suspicious Activity Reports (SARs)

You must submit a SAR if you know, suspect or have reason to believe a client is engaged in money laundering or terrorist financing.

Submit a SAR: SAR Reporting Portal

Failure to report could be a criminal offence. Submitting SARs shows your AML controls are active and working.

Verifying Overseas Clients

Certification Requirements:

  • Document must be certified as a true copy
  • Include the certifier’s name, signature, occupation, and contact details

Accepted certifiers include:

  • Bank officials
  • Lawyers or notaries
  • Judges or police officers
  • UK embassy staff (non-EU clients)

Translation Requirements:

  • Include translator’s name, contact, and official status

FATF Risk Considerations:

  • Check FATF black and grey lists
  • Avoid onboarding from black-listed jurisdictions
  • Apply EDD for grey-listed countries

Verification Tools:

💡 Flex Tip: Re-check overseas client records annually and always document clearly.

More Support

Flex AML offers tailored templates, policies and ongoing compliance support. If you need help implementing ID and POA checks, get in touch with our friendly team.

Please note: This guide is for internal use only. If you wish to share or adapt any part of this guide, contact us for permission.

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