Hello
How do I verify the identity of a potential client under the current circumstances? can I rely on digital ID verification given that meeting a client face to face may not be possible and getting a certified copy of documents may be just as difficult?
I assume that accountants who offer a remote bookkeeping/accountancy services rely on digital identification?
Thanks
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Replies (10)
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I am certainly doing so, and know many other colleagues are too. Of course you could always enquire further if any info supplied gave you any cause for concern for any reason.
Email from HMRC AML team this morning:
Dear customer,
As a business registered with HMRC under the Money Laundering Regulations (MLRs), you must verify the identity of customers as part of your Customer Due Diligence (CDD) requirements.
The UK government has made it compulsory to wear a face covering in shops from 24 July in England and it is already compulsory in Scotland.
People may also choose to keep a face covering on in other settings and may feel uncomfortable if asked to remove it.
If a customer is wearing a face covering, you must still apply your CDD policy. There are a range of e-verification tools that can be used to assist with this. If you cannot verify a customer’s identity, you should not proceed with the transaction or business relationship.
This kind of thing really has me "for heaven's sake" -ing.
If you are being presented with ID documents and other financial data and your only doubt about the subject stems from uncertainty about whether your visual impression of the lower part of their face matches their photo, then you have more problems than AML rules.
I think this guidance probably contravenes the DDA. You do not have to be fully-sighted to be an accountant.
Consider this
1 Get client to send copy of passport and driving licence to you by email
2 Have a video call with client with them showing the page on the passport so that you can see it is the same one and at the same time verify they are the passport holder.
3 Write to his/her current address and ask that they sign and return the letter
4 Get electronic AML certification
I do pretty much the same thing, depending upon the assessed risk (which is what we are supposed to do).
I get the new client to email/MMS copies of the photo ID and address ID and then, in a video meeting I ask them to show me the same documents. I then screenshot the video call so I have the evidence.
The process is really easy and I have been doing it for some time (even before Covid-19). In a recent CIOT AML training webinar, the CIOT confirmed this practice to be acceptable.
For those using electronic ID - how do you know the person who is sitting in front of you is the same person whose ID you are veryfying electronically? If they are not sitting in front of you how do you know who to identify electronically?
I had to provide ID myself for a mortgage at the start of lockdown and was told to take a picture of myself holding the passport open and upload that to their system. It worked.