ECSH33720 - Records testing: records in a foreign language

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) do not state that documents obtained to satisfy customer due diligence (CDD) measures must be in English.

Therefore, if a business provides you with copies of CDD documents in a foreign language, you will need to establish whether the business:

• Understands the information contained with them.
• Can explain what the document is and what it says.
• Can explain why it has been obtained and why it considers that the document mitigates a risk of money laundering or terrorist financing.

If the business understands the foreign language and can read the document to confirm its contents, you should assess if it verifies identity, as you would for any other document in English.

If not, ask the business what steps it has taken to satisfy itself that the documents provide evidence of the customer’s identity. For example, has the business obtained a certified translation of the documents? If it has used a translation website, use a risk-based approach to decide whether the translation confirms what the document is and what information it is verifying. For example, there is a lower level of risk in establishing that a document is a foreign utility bill for the purposes of verifying the customers address than a document showing a company’s articles of association for the purposes of verifying details of the body corporate.

You should obtain a copy of the document in the foreign language and obtain a translation of the document following the guidance for overcoming language barriers.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)