ICB understands that you are duly concerned about the impact that COVID-19 will have on your families, colleagues, friends, and businesses. The sad fact is that the criminal element in our society see such a crisis as an ideal opportunity to commit a crime and launder their proceeds through hard-pressed businesses and exploit the fact that professionals might not have their eye on the ball.
Compliance with the MLR 2017 is a legal requirement even in these unprecedented times and ICB will continue to supervise members' compliance albeit in a proportionate manner.
Applying CDD on new clients can be particularly difficult at a time when face to face meetings are to be avoided. Members should take a risk-based approach to their AML compliance and where appropriate to do so might seek to use online electronic identification verification checks, which since the introduction 5 EU MLD into UK law allows for this provided that the product used is free from fraud and relies on multiple information sources, you might also consider Skype/Zoom video calls with new clients prior to taking them on.
A word of warning here though, online electronic identity verification checks only to verify that a person exists, not that that person is your client. Also, beware of receiving copies of passports and other documents that might have been altered. It might be that you have to use a number of different measures together to satisfy client identity verification on high-risk clients.
It’s also timely to remind members of the need to carry out ongoing monitoring of your client’s businesses to ensure they are being run in line with your expectations and be on your guard for any unexpected changes.
ICB compliance team are working as normal and are here to provide information and support if required, we will post updates on the ICB website as and when required.