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What are some of the acceptable options for verification given that the majority of business is non-face to face during the COVID-19 pandemic?
The FSC is mindful of the challenges posed to conducting customer verification in the current environment of COVID-19, where curfew orders, social distancing, and self-isolation have become a part of our daily existence.
Emerging risks arising out of the current pandemic environment have been identified by the FATF, which makes it even more important to confirm that a client is who they say they are. Independent verification options are a critical part of the client acceptance process, particularly for ECDD purposes.
Section 23 of the AML/CFT Code of Practice provides for the acceptance of electronic/ digital verification of identity. The FSC does not wish to be overly prescriptive in outlining acceptable verification options; instead, customer verification options should align with licensees’ risk assessments of their clients. Accepted documents, electronic or otherwise, should fit with clients’ risk profiles and be subject to appropriate risk management processes.
As the AML/CFT Code of Practice requires you to take a risk-based approach to your operations, licensees should have client monitoring procedures commensurate with any risk assessment carried out.