Before you finish up for Christmas, take note that the AML/CFT Supervisors have this week released new and updated guidance. This includes a new Enhanced Customer Due Diligence Guideline and an updated Identity Verification Code of Practice (IVCOP) – Explanatory Note.
The IVCOP Explanatory Note finally provides some much needed clarification around electronic verification by making it clear that electronic verification actually has two key components. The first component is well understood, being the confirmation of identity information via one or two independent and/or reliable electronic source(s). The second is the requirement to match the person you are dealing with to the identity information you have verified. Both components must be satisfied. The note also provides examples of some additional steps a reporting entity could take to link the person to the claimed identity. It is the two components combined that enables reporting entities to be satisfied to a high level of confidence that they “know” who they are dealing with.
We will provide more information in the New Year, but do place reading and understanding the IVCOP Explanatory Note at the top of your 2018 “to-do” list - you can find it here.
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