What does the JMLSG Guidance Notes require for customer identification?
The revised JMLSG Guidance recognises firms will ‘in many situations need to be prepared to accept a range of documents, and they may also wish to employ electronic checks, either on their own or in tandem with documentary evidence’. The JMLSG Guidance also describe the benefits of a firm in seeking electronic evidence of a customer’s identity , either by accessing external electronic databases directly, or through ‘independent third party organisations’ Specifically, it says ‘the site of the electronic footprint in relation to the depth, breadth and quality of data, and the degree of corroboration of the data supplied by the customer, may provide a useful basis for an assessment of the degree of confidence in their identity’. (JMLSG Guidance, Part 1, paragraph 5.3.3.4). For further information on the JMLSG please see their website: www.jmlsg.org.
