Question to the HM Treasury:

To ask Her Majesty's Government whether all existing banking customers must provide proof of identification to banks to check for possible money laundering; if so, under which regulations this policy was brought in; whether an impact assessment was carried out on the costs to customers, particularly those in rural areas, of any such requirements; and what estimate they have made of the total cost of any such policy.

This question was answered on 18th June 2019
The Money Laundering Regulations 2017 (‘the Regulations’) do not require banks to carry out customer due diligence – including identity checks—on all existing customers. The Regulations instead require banks to take a proportionate approach to applying customer due diligence checks commensurate with the risk of money laundering. The legal requirements on banks to carry out customer diligence for existing customers are set out in Regulations 27(8)(9) and 29(7). The Joint Money Laundering Steering Group’s guidance provides further detail on applying these requirements.

The impact assessment for the transposition of the 4th EU Money Laundering Directive (which led to the most recent revision of the regulations) estimates the total cost of the changes made, while concluding that industry has difficulty in identifying costs caused by the money laundering regulations. This is particularly the case for customer due diligence as many of these are costs that a prudent business would take on in any case as a matter of commercial practice, to comply with UN or EU sanctions, or to protect themselves and their customers from fraud. The full impact assessment is available on gov.uk.