The current legislative regime for anti-money laundering places a substantial obligation on law firms to have robust procedures in place to manage and mitigate the risks associated with money laundering.
A significant part of this obligation involves undertaking due diligence to properly identify a client and the nature of its business as well as the potential risks involved in the work we are instructed to carry out.
Amiqus ID is the online tool we have chosen to assist with this diligence obligation. We use it to confirm and record identity and anti-money laundering checks for:
- Instructing company directors;
- Non-directors who are authorised to provide instructions on behalf of a client;
- Beneficial owners (individuals with at least 25% equity or who otherwise exercise ultimate control of a company)
- Investors; or
- Any other individual who is sufficiently involved in a transaction we are instructed in to oblige us to carry out identity and anti-money laundering checks.
Amiqus ID is provided by Amiqus Resolution Limited, a company incorporated in Scotland under company number SC511150 and with its registered office at CityPoint, 3rd Floor, 65 Haymarket Terrace, Edinburgh, EH12 5HD.
Amiqus Resolution Limited is the strategic partner of our regulator, The Law Society of Scotland, and the Society has promoted Amiqus ID to its members as part of a robust approach to anti-money laundering compliance.
Amiqus are acting as our processor under Data Protection legislation to help us carry our appropriate identity and AML checks. We are the (data) controller. Amiqus can only use the data you provide for the specific purpose we instruct them. The data you provide is retained securely in encrypted form by Amiqus in accordance with our instruction to them as our (data) processor.
Amiqus ID is certified by and exceeds the requirements set by the UK government cyber security accreditation scheme Cyber Essentials Plus. It is recommended by the Law Society of Scotland and includes the following security features:
- Data encryption: It uses SHA-256 encryption throughout all verification steps. This means that any data input to our systems for verification is securely sent and received. Data is also encrypted at rest when on our servers.
- Access controls: Access to user data is tightly restricted to only the authorised requesting firm with enforced password standards, activity reporting and account throttling. All passwords are hashed using SHA-512 with over 10,000 rounds, and a 32-byte salt of random data.
- Monitoring: All of its web traffic is encrypted over TLS /SSL and protected by Certificate Pinning to prevent man in the middle attacks. The Amiqus security team monitor and carry out daily automated vulnerability scanning across all of its systems and infrastructure.
- Infrastructure:Its servers are based within enterprise grade hosting facilities with robust physical security controls including surveillance, monitoring, security staff and regular ongoing audits. Amiqus maintains geographically separated environments and hosting to reduce the risk of data outages or loss. Amiqus partners with leading security and technology providers to leverage their experience and best practises to protect its systems.
- Assurance: Amiqus ID is certified by ISOQAR to ISO 27001:2013 and UK government cyber security accreditation scheme Cyber Essentials Plus.
- Analysis: Amiqus Resolution Ltd is a member of CiSP, the NCSC cyber threat sharing platform and benefits from ongoing analysis, reporting and monitoring of online activity on a national level.
There is a £15 administration fee for each check, which is normally included in the first client invoice.
When you receive your email from Amicus and are ready to start the verification process, click on the green “Start verification request” section of the email. On the next page, click on the “I agree to Amicus ID terms and conditions” tick box to notify your acceptance and then click on the green “confirm and continue” box. (flag to AH) Name Details
The next page will ask you for details of your title and full name. Insert your information into the appropriate boxes then click on the “I have read and understood the above and would like to proceed” tick box. Then click on the green “confirm and continue” button.
Address Details The next page to open will ask for your home address. You need to insert details of your current home address. If you have multiple homes or have recently moved, enter the most current information. The details you provide will be checked against the Electoral Roll, DVLA and Home Office databases and you need to supply details covering the last 12 months.
Additional Details Next you are asked to supply your date of birth, email address, mobile and landline numbers. If you do not have a landline you can leave this section blank. Click on the green “submit details and continue” button
Identity report You may be asked here to confirm how long you have lived at your current address. If you have lived at your current address for less than 12 months you will need to provide details of the other address or addresses where you have lived over the last 12 months. Click the green “continue” button
Photo ID Verification
You will be asked to upload a photo of your identification. You can do this using a smartphone/webcam or you may be able to scan your documents and upload the picture onto your computer. The easiest way to complete this section is by using a smartphone.
You will also be asked to take a picture of yourself showing a unique code that will be sent to you.
At the top of the page there is a link you can click if you want more information about the Photo ID Check which will take you to a separate webpage with a list of frequently asked questions and responses.
Once you have read the instructions and are ready to proceed, click on the green “continue” button. This will take you to a new page.
You will shortly be asked to take a picture of or upload a picture of your identification document. At point 2 you will see that a code number is displayed. Make a note of this number now as you will need it soon.
Next, click on either the passport, driving licence or identity card symbol depending on which form of identification you wish to use.
On the next page you will be given the option to use your mobile to take a photo of your identification or to upload a copy of a photo of your identification you have already stored on your computer.
If you are using your mobile, enter your mobile number and click on the green “send link” button. You will shortly receive a text with the heading “Verify ID” which contains a link. Click on the link and follow the instructions to take a photo of your identification. Click “ok” on the photo. You will then be given the option to redo or confirm the photo. If you are unhappy with the photo click “redo”. If you are happy with the photo, click “confirm”. You may then be asked to take a photo of the back of your driving licence or ID card and confirm this too.
If you are uploading a photo stored on your computer you will first need to scan in a copy of the document and upload this to your documents folder on your computer. Follow the instructions and links on screen.
The scan or photo needs to be in colour, in focus and all edges of the identification need to be shown.
Photo with Unique Number
Next you will be asked to take a photo of yourself with the unique code you noted down earlier. Once taken, click on “ok” if you are happy with the photo or “retry” to try again. When you are happy click the green “confirm” button to proceed. If the uploads have been successful you will be told to return to your computer screen to continue the process. Click on the green “submit photo ID” button.
What happens next
You have completed the process. MBM will now review your submission and will contact you if there are any issues. You will also receive an email confirmation.