Where you are acting for Public Trust, in these circumstances they will generally be acting as an executor of an estate. Public Trust therefore will be considered your client and subsequently you will need to conduct CDD on Public Trust, rather than any of the recipients of the estate property.
As Public Trust is a governmental agency, they are subject to simplified customer due diligence (Simplified CDD). For simplified CDD, there is no requirement to identify or verify beneficial ownership of the client, however you will need to identify the person acting on behalf of the client. This will typically be the Public Trust representative who has signed the agency agreement on behalf of the Public Trust, or anyone else giving you instructions in regard to the sale of the property. Therefore, you will need to collect the following:
Client’s full name – specifically Public Trust.
Confirmation of how the client qualifies for Simplified CDD – this may be an extract from their website, for example confirming that Public Trust is a governmental agency.
Person acting on behalf of – full name, date of birth and address.
Person acting on behalf of – authority to act on behalf of customer (i.e. how do you know they are able to provide instruction or sign the agency agreement, this may be an email signature or letter they can present you).
You will need to verify the individual acting on behalf of Public Trust’s name and date of birth using a document such as a passport.
Where you deal commonly with the same representative, you will be able to re-use the CDD information across multiple deals which would make the process more efficient.