Customer Due Diligence
At 192business it's our aim to make Customer Due Diligence (CDD) simple to help regulated firms meet AML requirements and get on with earning fees and acting for their clients.
Allied to our market leading CDD technology is our understanding of firms CDD requirements whether they be a law firm, a lender, an electronic money issuer or a money transfer business.
Here's a quick summary of relevant CDD aspects the most widely recognised set of AML guidance notes, the UK’s Joint Money Laundering Steering Group’s guidance notes, and where 192business can help:
Customer Due Diligence
Section 5.1.5 Customer Due Diligence
(a) Identifying the customer and verifying his identity (b) Identifying the beneficial owner, where relevant, and verifying his identity
Our CDD technology has been designed to ensure that firms can quickly and cost-effectively identify and verify all their customers using a mixture of global verification databases and unique ID document verification technology.
Risk Based CDD
Section 4.23 Risk Based Approach
(1) A customer identification programme that is graduated to reflect risk could involve: (a) A standard verification requirement for all customers (b) More extensive due diligence on customer acceptance for higher risk customers.”
The degree of due diligence must be in proportion to the risk involved in the customer relationship. Our CDD technology offers a variety of tools and data so our clients can use as few or as many ID check tools and databases as they wish.
What is defined as “high risk” necessitating enhanced CCD?
(1) Where the customer has not been physically present for identification purposes.(2) An individual meeting the definition of a PEP. (3) A high risk jurisdiction.
Our CDD technology can be triggered to run automatically when your firm encounters high risk customers and help you manage decisions in the client onboarding process.
What is verification?
“Section 5.3.2; Identification and verification of the customer
The verification consists of the firm verifying some of this information against documents, data or information obtained from a reliable and independent source.”
192business CDD technology is unique in that it uses both data & document verification tools using officially recognised data sources and technologies.
When must verification take place?
“Section 5.2.2 – Timing of verification
The verification of the identity of the customer and where applicable, the beneficial owner must…. take place before the establishment of a business relationship.”
CDD should be performed as part of account opening or client on-boarding and our CDD tools can be easily used by fee-earners, admin staff or the MLRO. The 192business CDD technology can work seamlessly as an integrated component of a transactional web site or as a back-office tool.
What level of CDD should verification tools deliver?
An electronic check that accesses data from a single source (e.g. a single check against the Electoral Roll) is not normally enough on its own to verify identity.”
One match on an individual’s full name and current address and a second match on an individual’s full name and either his current address or his date of birth.”
It uses a range of positive information sources that can be called upon to link an applicant to both current and previous circumstances”
It accesses negative information sources such as databases relating to identity fraud and deceased persons”
Our CDD tools check multiple databases including the Electoral Roll, Credit Reference data, mortality, fraudster, money launderer, sanctions and PEP databases that are updated in real -time.
If you would like to know more about how we enable firms with the market’s leading CDD technologies please email us here