Anti-Money Laundering Guidance Notes:
General:
Investors in any fund advised by WAY Fund Managers Limited must fulfil the United Kingdom's anti-money laundering requirements under The Money Laundering Regulations 2003 and in accordance with the rules of the Financial Services & Markets Act 2000.
Guidance Notes:
1. Details of all the individual Trustees is required (if more than two, then on a separate sheet);
2. All the individual Trustees need to sign the application form; verification is needed for each individual Trustee;
3. The Trust name can be included as a designation by writing it on the application;
4. If the investment is, for example, in a WAY Income Plan, where withdrawals are made on a periodic basis and the recipient of the funds is to be a party other than the Trust (i.e. the Beneficiary), the identity and address of that person also needs to be verified.
Savings Plans:
The following notes pertain to all savings plans, be they ISAs or simple UT/ICVCs. WAY Fund Manager's (WFM) current Money Laundering requirements are as follows:
1. Total savings plans £100 per month or less - No identification required - However, if there is an increment, at any time in the future, the full (up-to-date) identification will be required (therefore, it seems sensible to supply the full identification details up front);
2. Total savings plans £100 per month or more - Full identification required - For a normal lump sum application, WFM would be in receipt of a cheque, which will invariably be drawn on the account of the applicant, or on a client money account on behalf of the client. For savings plans, where all payments are collected by Direct Debit, the IFA needs to confirm that the bank account details appearing on the DD mandate are those of the applicant (see the Regulation 8 section (at the bottom of the certificate) in the Identity Verification Certificate (pdf version above), the relevant parts of which must be fully completed);
3. Plans being paid for by a spouse/partner of the applicant - In all cases, WFM requires full identification of both the applicant and the person paying the contribution. Of course, in the case of an ISA, only the legal spouse of the applicant can be a "third-party payee".
ISAs:
The following notes pertain to all ISA savings plans:
On the application form, either in the Declaration or where the details of the relevant Tax Year is inserted, the following words appear: Tax Year 200_/200_ and for each subsequent tax year until further notice.
The principal purpose of this statement is to ensure that ISA monthly savings plan can continue into each subsequent tax year, following the original application, without the requirement for the client to have to sign a fresh application form each tax year. It also means that lump sum investors do not need to complete fresh application forms for each tax year (provided that they have not missed one whole tax year since the original application was made).
WAY Fund Managers will not be in a position to accept an ISA monthly savings plan if the wording has been deleted. Such applications will be returned.
Cheques:
In order to comply with the UK law on money laundering, cheques must be drawn on your own account or a joint account with your spouse.
If you ask your bank or building society to draw the cheque, they must state on the cheque that the funds have been drawn from an account in your name. For example, the payee would be "WAY Fund Managers (Re: A. N. Other)".
Alternatively, ask them to write your name and address on the reverse of the cheque and add the bank/building society stamp and signature to confirm the money is drawn from your account
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