If you receive a letter from your bank asking for an updated copy of your payroll or income certificate, do not throw it away. Not because of having a regular and fluid relationship with the financial institution or, in the opposite case, by barely making use of a current account that warning ceases to be less pressing because if not, the bank will block the account without hesitation.
It is bound to do so by the money laundering prevention legislation, which was approved in April 2010 and which, five years later, during the spring of 2015, forced the bank to contact hastily with customers who had not yet done so. submitted their updated data. It was an intense countdown until April 30 of that year, when the five-year term expired after the approval of the law that the banks had to formalize this process. And its failure by customers who had not contributed their ID and payroll or updated income certificate on time, with which to identify themselves correctly, caused the automatic blocking of the account.
That was not an isolated event and even if a client is far from being suspected of money laundering, after some time he will have to update his data with the bank under the same threat of blocking the account. The 2010 Law on the Prevention of Money Laundering and the subsequent royal decree of 2014, which approved the regulations of the aforementioned law, establish that the Updating of customer data must be continued and on all customers.
"The obliged subjects (the banks) will periodically carry out review processes in order to ensure that the documents, data and information obtained as a result of the application of due diligence measures are kept up to date and in force," explains the royal decree, prepared by the Sepblac.
The text also adds that the periodicity of the review of clients' documents of a risk above the average will be, at least annually. In this category would enter foreign clients or public offices. The regulations therefore oblige banks to have a money laundering prevention manual in which to include the periodicity of updating customer data and, except for the most risky clients, it leaves the financial entities free to Establish the frequency of revisions.
In general, as recognized by banking sources, the updating of the data is every three years for those clients who are classified as medium risk and every five years for low risk clients.
"We inform you that, as long as we do not receive the requested documentation, we must proceed to establish operational restrictions and put an end to the business relationships we have with you," BBVA warns in a notification to clients. And if the documentation is not provided, the bank will reject all payments, debits and withdrawals that occur as of that moment. The regulation establishes that the requirement to provide proof of income extends to the account holders and also to the persons authorized therein, even if they do not register any operations.
Financial sources indicate that the request for updated data may not be necessary when there is a fluid relationship with the client, who has the payroll registered with the entity and who thus reports each month on their source of income. Although the money laundering prevention protocols may also require a reinforcement in that documentation control -like the presentation of the income statement-even if the payroll is registered, in order to verify that the employment is real.
The request to deliver the updated income data can be resolved in person at the bank office or online.
The deadlines for submitting the documentation can be very small since the bank's notification is received – either by email, by letter or by phone – so it is advisable to be alert to avoid blocking the account.
If the documentation is not delivered on time, blocking the account will mean the immediate return of the direct debits. And even if that account is unlocked later, if it has already been five days since the return of the receipt, the bank can not recover it and the affected customer will have to contact the electric or telephone company to request the charge back to the bank.