Private bank file redaction is the removal of personal data from a relationship dossier. These files attract the heaviest due-diligence duties: MLR 2017 reg. 33 requires enhanced measures for higher-risk relationships, and reg. 35 sets the regime for a politically exposed person, a family member or a known close associate — with the FCA's FG17/6 guidance (July 2017) warning firms not to de-risk indiscriminately. FCA SYSC 10.1 requires conflicts of interest to be identified and managed. Where the relationship spans borders, UK GDPR Art. 44 and Art. 46 govern the transfer, with the ICO's International Data Transfer Agreement available since 21 March 2022. anonym.plus marks each identifier locally, so the notes stay useful while the principal goes.
When this applies
A relationship dossier holds identity evidence, source-of-wealth narrative, mandate history and correspondence in one place. A file review, a correspondent institution or an internal audit needs the risk assessment, not the principal. You trim the personal parts before it circulates, especially if the copy will cross a border.
How anonym.plus handles it
- Open the dossier in anonym.plus on your device.
- Local OCR reads scanned correspondence and identity pages.
- The tool flags name, IBAN, passport number and contact data.
- Keep the mandate type, risk rating and source-of-wealth reasoning.
- Swap or black out the marked items.
- Save the clean copy locally.
What you need to provide
- The relationship dossier (PDF, DOCX, mixed).
- An operator (Replace keeps the notes readable).
- Optional alias map for the principal across linked files.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | the relationship holder → [PRINCIPAL] |
| Financial | IBAN_CODE | GB29 NWBK 6016 ... → [IBAN] |
| National ID | NATIONAL_ID | passport no. → [NATIONAL_ID] |
| Money | MONEY | funds £12.4M → [VALUE] |
| Contact | PHONE_NUMBER | +44 20 7946 0501 → [PHONE] |
| Location | LOCATION | residence → [ADDRESS] |
Compliance achieved
- MLR 2017 reg. 33 requires enhanced due diligence for higher-risk relationships, and reg. 35 sets the regime for a politically exposed person, a family member or a known close associate — the reason these dossiers hold so much data in the first place.
- The FCA's FG17/6 guidance on politically exposed persons (July 2017) expects a proportionate, risk-based approach rather than blanket refusal; the reasoning in the file matters, so keep it while removing the person.
- FCA SYSC 10.1 requires conflicts of interest to be identified, recorded and managed — a redacted dossier lets a conflicts reviewer see the pattern without seeing the client.
- If the copy leaves the UK, UK GDPR Art. 44 and Art. 46 govern the transfer; the ICO's International Data Transfer Agreement has been available since 21 March 2022. Removing the personal data first is usually the simpler route.
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Limitations & cautions
A dossier is dense with indirect clues — a residence, a source-of-wealth narrative, an unusual mandate — and a source-of-wealth story can identify someone on its own. The tool flags named items, not narrative inference, and it does not decide whether reg. 35 applies. Read the notes before you share.
Frequently asked questions
Why do private bank files carry more data than other client files?
Because MLR 2017 reg. 33 requires enhanced due diligence for higher-risk relationships, and reg. 35 adds senior-management approval, source-of-wealth evidence and enhanced monitoring for politically exposed persons. The extra evidence is deliberate, which is exactly why a shared copy should be minimised.
Can the mandate details stay?
Yes. Allow-list mandate type, risk rating and product codes. Only personal identifiers are marked, so a reviewer can still test whether the risk assessment holds together.
What if the review team is outside the UK?
Then UK GDPR Art. 44 and Art. 46 apply to the transfer, and the ICO's International Data Transfer Agreement (available since 21 March 2022) is one route. Removing the personal data before the file travels avoids the question entirely.