What is required of you?

In essence you are being asked to re-identify or confirm the identity of all your existing customers, both personal and business customers.

There are guidelines set out by the FSA stating how this exercise should be undertaken. For example

"Each bank will agree with its FSA supervisory team the specific details and a reasonable and realistic time scale for the exercise. The design and application of the framework takes account of the ongoing relationship which banks will have had with their existing customers and the banks' historic, current and future monitoring of their accounts for suspicious activity".

In addition the core principles behind the Current Customer review are:

• use of an appropriate filtering process to eliminate those customers who do not require their identity to be reconfirmed.

• the adoption of a risk based approach to the remaining customer population with the priority being given to high-risk categories.

• use of trigger events in appropriate cases to review customer identification

• the use of adequate systems to track progress, and monitor completion of the programme.

• the use of standard communication explaining the need for the banks to obtain identification

• where different UK regulated firms in the same group share a customer or transfer a customer between them, either firm can rely on the other firm's application of these notes to the relevant customer