At a glance
A sound file shows whose information was collected, the sources used and the date it was verified.
In this article 2 min read
Separate the roles in the documents
Rosfinmonitoring's guidance treats identification of clients, representatives, beneficiaries and beneficial owners as work involving different categories of information. The materials obtained form the client file. The requirements applicable to an organisation depend on its activities and supervision. [1]
Describe the source of each item of information
For each field, it is useful to state where the information came from: a client document, register, questionnaire or other source. Retain the date obtained and related materials. This distinguishes verified information from an entry copied without verification and makes the basis of the latest update traceable.
Look beyond job titles
Representative information helps establish who acts for the client and on what authority. Ownership and control information serves a different purpose. When checking forms, make sure these roles are not combined in one field and that authority documents do not replace examination of the ownership structure.
Check that records are consistent
Compare names, identifiers, dates and roles in the questionnaire, supporting documents and system used. If the information differs, record the nature of the discrepancy and the clarifications needed. Rewriting a questionnaire without retaining the basis of the change makes the client's history harder to analyse later.
Agree the scope of an external review
A consultancy review may cover questionnaire forms, a process description and an agreed sample of files. It does not require sending the entire client database by ordinary email. The necessary scope, lawful basis for transfer and way of handling materials are determined in advance; the result is a report on the specific elements checked.
Official sources
Sources checked on 24 October 2026. Practical recommendations on preparing materials are provided by the AML Expert editorial team. The procedure for a specific case depends on the documents and the applicable basis.