When clients require notarial services, they are sometimes surprised by the level of identification, verification, and due diligence that may be requested before documents can be notarised.
As a Notary Public regulated through the Faculty Office of the Archbishop of Canterbury, notaries are subject to strict professional and regulatory obligations designed to combat money laundering, terrorist financing, and financial crime.
These obligations arise principally under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended, together with other legislation including the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
In this article, I explain why notaries undertake anti-money laundering checks and what clients can expect when seeking notarial services in 2026.
Why Are Anti-Money Laundering Checks Necessary?
Money laundering is the process by which the proceeds of criminal activity are disguised to appear legitimate. Terrorist financing involves providing funds or resources that may be used to support terrorist activities.
Professional services and notarial services, can sometimes be targeted by criminals seeking to give legitimacy to transactions, corporate structures, property dealings, or international transfers.
The anti-money laundering framework of England and Wales, requires regulated professionals to take a risk-based approach to identifying and preventing financial crime. This includes understanding who clients are, why a transaction is taking place, and whether there are any indicators of suspicious activity. Government guidance continues to emphasise the importance of customer due diligence, risk assessments, beneficial ownership checks, and ongoing monitoring where appropriate.
Why Does a Notary Need Proof of Identity?
One of the most common questions clients ask is:
“Why do I need to provide identification when I only need a document notarised?”
The answer is straightforward. A notary must be satisfied as to the identity of the individual signing a document and, in many cases, the capacity in which they are acting.
Typically, clients may be asked to provide:
- A valid passport
- Photographic driving licence
- Proof of residential address
- Corporate documentation where acting on behalf of a company
- Evidence of authority to sign
The purpose is not simply to verify identity but to ensure that the transaction is genuine and that the notary can confidently certify the authenticity of the signature and underlying documentation.
Understanding Source of Funds and Source of Wealth
In some circumstances, clients may be asked additional questions regarding:
- Source of Funds
- Source of Wealth
Although these terms are sometimes confused, they have different meanings.
Source of Funds
Source of Funds relates to the origin of the money involved in a particular transaction.
Examples may include:
- Employment income
- Sale of property
- Inheritance
- Business profits
- Investment proceeds
Source of Wealth
Source of Wealth refers to how a person has accumulated their overall wealth over time.
Examples may include:
- Long-term employment
- Ownership of a business
- Property investments
- Family inheritance
- Successful investments
Where a transaction involves significant assets, overseas jurisdictions, corporate structures, trusts, or higher-risk circumstances, a notary may need to obtain evidence supporting these matters.
Beneficial Ownership and Corporate Clients
Corporate and business transactions often require additional scrutiny.
Where a company is involved, a notary may need to identify the individuals who ultimately own or control the organisation. These individuals are commonly referred to as Ultimate Beneficial Owners (UBOs).
This may involve reviewing:
- Company incorporation documents
- Registers of shareholders
- Corporate structure charts
- Trust documentation
- Board resolutions
Understanding beneficial ownership is a key component of the anti-money laundering regime of England and Wales and helps prevent the misuse of corporate structures for illicit purposes.
International Transactions and Higher-Risk Jurisdictions
Notarial services frequently involve documents intended for use overseas.
Examples include:
- Powers of Attorney
- Property transactions abroad
- International company incorporations
- Overseas bank account documentation
- Immigration and visa applications
- International inheritance matters
Where documents relate to higher-risk jurisdictions or complex international structures, enhanced due diligence may be required.
This does not mean that anything improper has occurred. Rather, it reflects the risk-based approach expected of regulated professionals under the legislation of England and Wales.
The Importance of Record Keeping
Notaries are required to maintain appropriate records relating to client identification and due diligence.
These records assist in demonstrating compliance with regulatory obligations and help ensure that appropriate safeguards are in place against financial crime.
Clients can be reassured that information obtained during the due diligence process is handled professionally and in accordance with applicable legal and regulatory requirements.
Professional Regulation and Public Confidence
The legal and professional sectors continue to play a crucial role in safeguarding the integrity of the City of London financial services system.
Regulators and supervisory bodies increasingly expect regulated professionals to maintain robust systems, controls, and procedures to identify and manage money laundering and terrorist financing risks. Recent regulatory reviews have reinforced the importance of effective anti-money laundering supervision across the legal professions.
As a Notary Public, my role is not only to authenticate documents but also to ensure that the services provided meet the high standards expected of an internationally recognised legal profession.
Conclusion
While requests for identification, proof of address, source of funds information, or corporate documentation may sometimes seem extensive, these checks form an important part of protecting clients, businesses, and the wider public from financial crime.
The Money Laundering, Terrorist Financing and Transfer of Funds Regulations continue to place significant responsibilities on regulated professionals in 2026 and beyond. By undertaking appropriate due diligence, notaries help ensure that international documents can be relied upon with confidence both in the United Kingdom and overseas.
If you require notarial services and have questions regarding identification requirements or anti-money laundering procedures, it is always advisable to discuss these matters with your notary before your appointment so that the process can be completed efficiently and without delay. Please contact us if you have any queries.