The Money Laundering Regulations permit the electronic verification of the identity of individual or a company. Electronic verification is sufficient on its own to verify the identity of an individual, or indeed a company, when the insolvency case has been assessed as a “normal” risk case such that only normal customer due diligence needs be undertaken. Where the case has been assessed as a “high” risk then it can form part of the enhanced customer due diligence required.
You could consider using electronic verification either as an alternative to requesting evidence of identity in all “normal” risk cases, or as a fall back position should an individual whose identity you are seeking to verify does not provide the necessary documentation. Given how quick, easy and cheap electronic verification is then this is something that you should certainly consider.
There are a number of organisations that now offer electronic verification services, such as CallML, 192business or Equifax, but before deciding which one to use you need to ensure that they the information they provide is sufficiently reliable, comprehensive and accurate to enable it to be used as verification of identity, taking into account the following points:
• Does the system draw on multiple sources? A single source is not usually sufficient. A system which uses both negative and positive data sources is generally more robust than one that does not.
• Are the sources checked across a period of time? Systems that do not regularly update their data are generally prone to more inaccuracies than those that do.
• Are there control mechanisms to ensure the quality and reliability of data? Systems should have built-in checks that ensure the integrity of data and should ideally be transparent enough to show the results of these checks and their bearing on the integrity of data.
• Is the information accessible? Systems need to allow a business either to download and store the results of searches in appropriate electronic form, or to print off a hardcopy record containing all necessary details as to name of provider, source, date etc.
