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For starters: Our company is based in Germany and thus is based on German law.

Germany now has adopted a new act regarding anti-money laundering and which information needs to be stored.

Now we're forced to provide our customers (real estate agencies) with the possibility to store passport information alongside a customers record.

I do not want to participate in any security-discussions, since this whole thing is going to be heavily encrypted anyway, so security should be out-of-scope.

I'm more wondering on how to design such an SQL Server table to be ready for international passports and "identity documents". Are there information that ANY country specifies in their passports, some international standards or such?

Which columns would be needed to conform to other countries' anti money-laundering laws?

  • I guess the easiest would be to ask a real estate agency what kind of passport information they are required/would like to store. Passports for international travel all have pretty much the same information printed in them, regardless of the issuing country. – mustaccio Apr 2 '14 at 17:00
  • @mustaccio That's exactly what I'm asking for. The agencies itself would like to store everything that's readable on a passport, but what I'm asking for is the information that's printed in them, regardless of the issuing country. I guess I'm not the first with this "problem", so this should've been done sometime before? – SeToY Apr 2 '14 at 17:08
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According to this information on the ICAEW site, the things to be copied are fairly well defined. This is based in the UK. See:

http://www.icaew.com/en/members/practice-resources/news/money-laundering-what-do-you-do-with-passports

Basically they say that identification: "For the purpose of due diligence evidence under the Money Laundering Regulations you may copy the personal details page only.

HM Stationery Office (HMSO) guidance also makes it clear that passport photocopies must be in black and white only, so that they cannot be mistaken for an actual passport page.

Furthermore, you are only allowed to copy the details page."

The HMSO (Her Majesty's Stationary Office) has similar details.

http://www.hmso.gov.uk/copyright/guidance/gn_20(old%20format).htm

So it seems that if you preserve a black and white copy of the personal details page, you are complying. Of course, the one who makes the copy (or scan) should verify personally against the original passport that the bearer is indeed the person described.

The verification process may be more stringent depending on where you are.

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