Client verification Current

Verifying a client's authority to instruct on behalf of an entity

A practical checklist for confirming authority before engagement work begins.

Someone claiming to instruct you on behalf of a company or trust isn't the same as someone who actually can. This guide sets out a practical checklist for confirming authority to instruct. It reflects Vertical Flows' own operational practice, not a regulator's own checklist.

Action plan

1 Identify the capacity the person is instructing you in A director, an authorised officer, an agent, and a trustee each need a different kind of authority check.

Before relying on instructions, identify the specific capacity the person claims to be acting in, for example as a company director or officer, an authorised employee, an agent under a power of attorney, or a trustee. The right authority check depends on which of these applies.

  • Ask directly what capacity the person is instructing you in
  • Don't assume capacity from context, such as an email address or a familiar name
  • Note the claimed capacity before checking it

Done when: The instructing person's claimed capacity to act for the entity has been identified

See requesting a signed authority to act
2 Verify the actual basis for that authority The claimed capacity needs its own supporting document, not just a client statement.

Each capacity has its own evidence: a director or officer's authority can generally be checked against the company's own register and governing documents; an agent's authority against a power of attorney or letter of authority; a trustee's authority against the trust deed's appointment provisions.

  • For a director or officer, check the company's register and governing documents
  • For an agent, request the power of attorney or letter of authority itself
  • For a trustee, check the trust deed's appointment provisions

Done when: The instructing person's authority has been verified against the document that actually establishes it

See verifying a trust's structure and trustees
3 Re-check authority if the person or entity structure changes Authority verified once doesn't necessarily carry over if the instructing person or the entity changes.

If a different person starts instructing you, or the entity's structure changes, such as a new director, a revoked power of attorney, or a new trustee, re-check authority rather than assuming the earlier verification still applies.

  • Re-check authority when a different person begins instructing you
  • Re-check authority when the entity's structure or officeholders change
  • Document each re-check and its outcome

Done when: Authority has been re-checked whenever the instructing person or the entity's structure changed