Nolans - AML Data Collection - AML & FATCA & Tax Questionnaire (Trust)

If the customer is a Trust - this interview should be used

by Nolans Lawyers

Who Should Complete this Interview?


If the customer is a Trust - this interview should be used. This interview will gather information on the trust's beneficial owners, and the people who act on the trust's behalf in order to assist with customer due diligence (‘CDD’).


If the customer is the Trustees - then customer due diligence (‘CDD’) needs to be completed on each trustee, and on any individual that either:

a) owns more than 25% of a trustee, or

b) has effective control over a trustee. 

In this case, each trustee or individual owning more than 25% of a trustee should complete the INDIVIDUAL INTERVIEW.

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For the Customer:

This product will assist your lawyer to capture and retain centralised data about you, which they are required to do by law. Your lawyer should advise you on what they use this information for and how they retain it. If you have any questions about this please ask your lawyer.


For the Lawyer

This product will assist you to capture and retain centralised data about your clients which may assist you in completing your customer due diligence requirements and your reporting obligations.


The purpose of this AML product is data collection. A report is generated from the data collected which sets out a summary of the data collected. ID and proof of address requirements are addressed in the report.


The AML/CFT Act requires customer due diligence to be conducted on all customers, beneficial owners of customers and any person acting on behalf of a customer.


Standard customer due diligence is the most common type of customer due diligence to be conducted and this interview will assist in collecting the information required to meet those obligations. It will identify the documents the customer is required to provide, and create a "checklist" of these documents.


Enhanced due diligence (EDD) is required in certain cases - this interview will assist in identifying some of the circumstances when EDD is appropriate. If you intend to verify identity through documents, it will identify the documents the customer is required to provide and produce a "checklist".


Disclaimer: please note that this is a tool designed to aid the capture of client data which assists with the client due diligence required under the AML/CFT Act. It is not a complete solution for CDD, verification is required. The end report addresses how this can be achieved.


This tool in itself does not discharge any obligation you may have to meet requirements under the AML/CFT Act or any other legislation, regulation or other rule. This is a tool for compliance only and does not constitute legal or other advice. The obligations to comply with CDD requirements remain with the relevant reporting entities.

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