Are excessive AML checks delaying customers accessing their own money?
Financial adviser Scott Gallacher has questioned whether excessive anti-money-laundering checks are creating unnecessary delays for clients trying to access their own money.
Gallacher, a Director at Leicester-based Chartered financial planners Rowley Turton, raised the issue after encountering what he believes is a disproportionate ID requirement from ReAssure.
The case involves a long-established trust which needs to withdraw just a few hundred pounds to pay its annual legal fees. The identities have previously been verified.
ReAssure requested ID and was provided with a valid passport and driving licence. The driving licence also confirms the client's current address.
But ReAssure says this isn't enough. Because both documents fall into its "List 1", it also wants a utility bill, bank statement or council tax statement for the current tax year.
Gallacher said:
"I've got absolutely no problem with providers carrying out proper anti-money-laundering checks. We all want that.
"But this is a long-established trust, the identities have previously been verified and we're taking out a few hundred pounds to pay the annual legal fees. We're hardly dealing with a suspicious multi-million-pound transaction.
"The client has provided a passport and driving licence, and the driving licence confirms their address. Yet apparently we still need another document because both pieces of ID happen to sit on the same ReAssure list.
"My question is a simple one. What additional money-laundering risk is that utility bill or bank statement actually addressing?
"JMLSG guidance is supposed to be risk-based. Consumer Duty also specifically talks about firms asking customers for unnecessary information or evidence and creating unreasonable barriers.
"Of course there will be cases where additional checks are needed. But surely there has to be some common sense and proportionality as well.
"If a provider already knows who the client is, has previously verified them, has two current pieces of ID and is dealing with a routine withdrawal of a few hundred pounds from a long-established trust, how much more evidence do they reasonably need?
"AML rules are there to prevent financial crime. They shouldn't become a convenient excuse for unnecessary bureaucracy that delays people getting their own money."
Questions for other experts
- Have you encountered similar ID demands from ReAssure or other providers?
- Are some providers going unnecessarily beyond JMLSG guidance rather than taking a genuinely risk-based approach?
- And are excessive AML checks now creating unreasonable barriers for customers under Consumer Duty?



