IDV obligations as ACSP formations agent

Information
1

Hi,

We are a registered ACSP and act as a formations agent for our customers. We only form companies and only for single shareholders, we do not offer additional filing services. We currently ID check all of our customers for internal AML/KYC etc.

I’m unclear from the documentation what our obligations are come 18 Nov, and having attended a couple of webinars I’m sadly still a little lost.

  • Do we (legally) need to provide the ID verification code in the incorporation XML request? Or can the director provide that at a later date, post-formation?
  • If we do need to provide the verification code in the incorporation request, where do we get that from? Do we need to register our IDV result in the web portal and wait for the customer to be emailed their code, for them to enter it into our system to continue?

Many thanks.

Rich K

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Disclaimer: Am not affiliated with CH, this is just my take from someone in a similar position to you.

It’s easier if you think of verifying someone as a completely separate process to incorporation (and hence your roles as a ACSP and formation agent being distinct). Someone can self-verify through CH, or you can do it for them as an ACSP. The end result of this process is the individual being verified by CH and being sent a personal code.

When you incorporate a company as a formation agent you need to supply the personal codes for all directors on incorporation, there is no opportunity to do it later (PSCs is a bit more complicated so won’t worry about that for now). At this point it doesn’t matter where, how or who got the code.

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