(context of the question is the UK but it may be relevant to other jurisdictions too)

I’m aware that under AML regulations, companies are expected to identify their customers and verify their identity: https://www.legislation.gov.uk/uksi/2017/692/part/3#regulation-28-2-a, and while it’s not explicitly stated there that it includes obtaining their residential address, it is stated in some separate guidance: https://www.gov.uk/guidance/money-laundering-regulations-your-responsibilities#customer-due-diligence-requirements.

For a privacy-conscious customer (who’s not planning to engage in money laundering), would it be legal to provide a virtual address for this to financial companies they engage with (mainly investment companies)? The virtual address service provides mail scanning/forwarding, so practically if the only use of the address to the company is for mailing statements etc. then that much isn’t a problem. Providing Proof of Address wouldn’t necessarily be an issue if e.g. the companies accept bank statements, as the customer can just have their bank issue their statements addressed to there. Essentially is the customer required to give an address distinct from their mailing address if they don’t live at their mailing address?

Is there actually any official legal definition of ‘residential address’ that would rule out using a virtual address? What would people who don’t have a permanent residential address like travellers be expected to provide as their residential address? Bearing in mind that, as stated above, the wording of the regulation simply requires ‘identifying’ the customer, so shouldn’t a unique virtual address with which they ‘identify’ for practical purposes be acceptable, even if they don’t live there? What exactly makes the place where they physically stay legally important in this regard?

Insofar as using a virtual address wouldn’t be legal, then who is it that’s actually responsible for committing the illegal act, the customer who gave that as their address (especially if no further info had been provided on what constitutes a valid address), or the company that accepted it and didn’t confirm it meets whatever the required criteria of a ‘residential address’ are? It’s the companies that are addressed by the AML regulations so isn’t it their responsibility? Is the customer expected to provide them with any info beyond what they ask for and accept?


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