Know Your Member (KYM)

This policy sets out how Redwood Estate Planning approaches member identification, due diligence, and the handling of any concerns that arise in the course of providing guidance and preparing documents. It reflects both our legal obligations and our own standards — which in some respects go further than the law requires.

Our position on regulation

Will writing and estate planning are not currently supervised sectors under the Money Laundering Regulations 2017. Redwood Estate Planning is therefore not subject to the formal Anti-Money Laundering regime that applies to solicitors, accountants, and financial advisers. We are not registered with an AML supervisory body, and we are not required to be.

However, the Proceeds of Crime Act 2002 applies to everyone — regardless of sector. If we know or suspect that a transaction or arrangement involves the proceeds of crime, we have a legal obligation to report it to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR), and we take that obligation seriously.

Beyond our legal obligations, we apply our own standards of due diligence — because we believe it is the right thing to do, and because the nature of estate planning means we are often trusted with sensitive personal and financial information.

What we need from you — and why

Before we begin preparing any documents, we ask all new members to provide proof of identity. This is standard practice across the profession, and it protects both our members and the integrity of the documents we prepare. We require one of the following:

Photographic ID

A valid passport or full driving licence. This confirms your identity and, in the case of a driving licence, your current address.

Proof of address

A utility bill, bank statement, or similar document dated within the last three months, confirming your current residential address.

We don't need — and don't ask for — a full picture of your financial affairs in order to prepare a Will or LPA. A Will looks after whatever is left in your estate when you die; an LPA puts the people you trust in control of your affairs if you lose capacity. Neither requires us to know the precise value of every asset you own. If you choose to share more detail, we can often help more — but that is entirely your decision.

"We ask for ID not because we doubt the people we help, but because it's the right foundation for any relationship built on trust — and because the documents we prepare can have significant consequences for the people you love."

More complex matters — property and trusts

Where a member wishes to place a property into trust — for example, as part of a lifetime trust arrangement — additional checks are required that go beyond our own due diligence. In these cases, we work with a qualified Doctor of Law who carries out the necessary identity and ownership verification checks prior to any activity being carried out, including any updates to the Land Registry title. This ensures that the appropriate level of scrutiny is applied where the stakes are highest, and that all parties involved are properly protected.

How we assess members

Alongside formal identity checks, we rely on professional judgement and discernment built through years of experience in this field. We pay attention to how members present themselves, the questions they ask, the instructions they give, and whether anything about a situation feels unusual or inconsistent. We don't believe in treating every member as a suspect — but we do believe in trusting our instincts when something doesn't feel right.

Politically exposed persons

We are alert to members who may be politically exposed persons (PEPs) — individuals who hold or have held prominent public positions, or who are closely associated with someone who does. We apply additional care and scrutiny in these circumstances.

Unusual instructions

Instructions that seem designed to obscure the true purpose of a document, or that don't make sense in the context of what we've been told, will always prompt further questions — and may result in us declining to proceed.

Inconsistencies

Where information provided seems inconsistent — between what someone tells us and what documents or other information suggest — we will always raise this and seek clarification before proceeding.

Pressure or urgency

Unusual pressure to complete documents quickly, or to proceed without completing identity checks, is itself a cause for concern. We will not be rushed into producing documents where proper process hasn't been followed.

Our right to decline

As set out in our complaints procedure, we reserve the right to decline to assist anyone — at the outset or at any point — where we feel, in good conscience, that the relationship isn't the right fit. This applies equally where something about a member's instructions or circumstances gives us cause for concern, regardless of whether we can point to a specific rule that's been broken. Professional judgement is not something we apologise for.

Suspicious activity — our obligations

If at any point we know or suspect that a member's affairs involve the proceeds of criminal activity — including tax evasion, fraud, or any other criminal conduct — we are legally required under the Proceeds of Crime Act 2002 to submit a Suspicious Activity Report (SAR) to the National Crime Agency, without notifying the member that we have done so (known as the "tipping off" prohibition). This is not discretionary. Where this situation arises, we will take appropriate legal advice before proceeding.

Record keeping

Copies of identity documents provided by members are retained securely for the duration of the relationship and for a reasonable period thereafter, in line with our data protection policy. Records of any concerns raised, decisions made, or referrals to the NCA are retained separately and indefinitely.

Record type

Identity documents - Duration of relationship plus a reasonable period thereafter

Member correspondence & files - As per data protection policy

Suspicious activity records - Retained indefinitely

Responsibility for this policy

This policy is the responsibility of Aaron Flack, Founder of Redwood Estate Planning. It is reviewed periodically and updated where necessary. If you have any questions about this policy or how it applies to you, please get in touch directly.