For adviser use only.

Where we refer to ‘we’ or ‘us’, we are referring to Timeline Platform as provided by Timeline Portfolios Ltd, which is authorised and regulated by the Financial Conduct Authority (number 840807).

Where we refer to ‘you’, we are referring to the adviser.

What are anti money laundering requirements?

All businesses providing banking and investment services to UK residents are required to verify the identities of all their customers to help combat financial crime and terrorist financing under the Money Laundering Regulations.

At Timeline Platform, we will always attempt to verify your client’s identity, often referred to as ‘Know Your Client’ (KYC), through a fully automated, electronic check. In instances where we're unable to verify their identity using automated checks, we will ask to see documents confirming their identity, residential address and/or bank details.

How does Timeline Platform verify my client's identity?

Once you begin an application to onboard a client to Timeline Platform, the primary method of performing a KYC check is comprised of two elements – a database identity verification check and a ‘liveness check’ which takes the form of either a successful electronic bank account verification or the provision of one form of government identification ‘Gov ID’ document plus a ‘selfie’. Both elements need to be successful for our KYC requirements to be fulfilled. There is, however, some flexibility in how we can achieve this.

The database identity checks are performed through our integration with an online identity verification service called Persona. Persona is a fully regulated entity providing KYC services in the UK and abroad, which will manage client data in compliance with UK data protection laws.

Persona will check the information provided as part of the client onboarding process against the following 3 data points on resources such as the UK electoral roll and online credit reference agencies:

· Name

· Date of Birth

· Address

If one or more of these data points does not match, the database verification element of the KYC check will be deemed by Persona to have failed, and we will reach out to the client to request one or several pieces of verification documentation depending on which data points were not successfully verified. A secure upload link, provided by Persona, will be sent directly to your client via email for each piece of documentation required.

In addition to the above, we will also capture and perform a verification check on your client’s bank account details via an integration with a separate online identity verification service called Northrow. Like Persona, Northrow is a fully regulated entity providing KYC services in the UK, which will manage client data in compliance with UK data protection laws.

In the event that this check fails, we will contact your client to request a copy of their bank statement, one form of Gov ID, and a ‘selfie’. If a Gov ID and ‘selfie’ were already captured in response to a failed database check, only a copy of the bank statement is required at this stage.

What documents can you accept?

The following is a breakdown of the documents we can accept in the event one or more database checks fail:

Please note that we cannot accept the same document to cover more than one failed check, except when verifying both a name and date of birth. This means that if an application fails the name, date of birth, and address checks, and a driver’s licence is used to verify the client’s address, we will require a copy of the client’s passport to verify their name and date of birth.

Any document uploaded via Persona must be dated within the last three months and must clearly display their name and home address. Bank statements must also include the account number and sort code.

Can you accept certified documents?

In the event your client is unable to directly provide any of the above documentation or cannot provide a ‘selfie’ through the email link provided by Persona, we will also accept copies of all the documents listed above if certified by you as a registered Financial Adviser or a valid certifier as listed below:

· bank or building society official

· councillor

· minister of religion

· dentist

· chartered accountant

· solicitor or notary

· teacher or lecturer

We cannot accept certification from any of the following:

· Anyone directly related to the client

· Anyone living at the same address

· Anyone in a relationship with the client

The document certifier must certify the document in line with the following requirements:

· writing ‘Certified to be a true copy of the original seen by me’ on the document

· signing and dating it

· printing their name under the signature

· adding their occupation, address and telephone number

Are there any additional checks?

In addition to the KYC checks listed above, Persona will also screen clients to determine whether they are categorised as a Politically Exposed Person (PEP) or subject to any active sanctions.

If a client is identified as a PEP, the application will be reviewed and either approved or rejected at our discretion. If the client is flagged as someone who is currently on any government sanctions list, we will not be able to onboard them.

Timeline Platform reserves the right to decline the application of any individual identified as a PEP or as having active sanctions against them.