Combine customer research with working from home; how do you do that?
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In short
Working from home is the new norm, and although it was a bit of a switch, many organisations and their employees have now found their way around it. Video apps like Zoom and Teams have become household staples and just about all the rooms in the house have already been used as workplaces. In many cases, working from home does not cause problems, but how do you carry out a proper client survey if you cannot meet the client in 'real-life'? Take, for example, the identification requirement: you need to identify the client and verify their identity, so you ask for a copy of their passport. However, the client refuses to provide these personal documents online. How do you ensure that your client can still share his/her documents with you safely?
Identifying the client
To identify the client, as described in the AFM's guidelines, you can simply use the data as provided by the client himself. You can have the client fill in the data via your own secure website or, you can go through Zoom or Teams to discuss this in “person”.
Identity verification is usually done by means of a valid passport, identity card, or driving license. People often don’t like sharing these documents over the internet. However, the Government has developed an app that makes these documents a lot less prone to fraud, and where they can be shared safely. This is the ID Copy app. The app gives your clients the ability to easily hide data (which you don't need to see) and to insert a watermark.
Below you will see a video explaining clearly how a copy of the ID can be made less fraud-prone through the ID-Copy app. More information about the app can be found on the website of the National Government.
Please note that you do need to check whether the client really has the document and that it is not a submitted copy of the Internet. For identifying the client, it would be best to schedule an appointment for a video call in which you first review the personal data, then check whether the person does indeed have the document, and then refer the client to the ID-Copy app. The client can share his personal information so securely and you can identify your client in accordance with the AMLD.
Obtaining an UBO statement
To prevent criminals from hiding behind a legal entity, you as a gatekeeper are obliged to establish the identity of the UBO (Ultimate Beneficial Owner). First of all it is necessary to investigate who the UBO(s) are behind the legal entity. You could find out the UBO through the UBO check of CDD On Demand. For more information about the UBO check, please click here. After the structure of the legal entity and the UBO(s) have been established,you must have it verified for the client.
There are multiple possibilities to do this. If you use the UBO check in CDD On Demand, you will receive a UBO report afterwards. This contains all the results from your UBO check. When you have such an UBO report, you can share it with your client and ask if the results are correct. You can also ask the client to share the data with you. In this case, you still need to check that this information is correct. Once all the data is correct, have the document containing all the data be signed by (the UBO(s) of) the client.
Compliance check
After you have checked the UBO’s it is necessary to screen the UBO’s, companies, and natural persons with whom you want to do business against various risk factors. CDD On Demand makes it easy to perform this screening without bothering the client with all sorts of annoying questions. At the end of the investigation you will receive a certified report as evidence for the compliance screening.
Monitoring
You have performed the compliance screening, you have assessed the risk, and finally engage in a business relationship with your client. From now on, it is important that you continue to monitor the risk assessment for any changes. In CDD On Demand, you can quickly add your clients to a monitor list where your clients are monitored daily using different risk components. As soon as something changes in the status of (one of) your clients, you will receive an email and you can take steps if necessary. If the risk of the business relationship has become unacceptable, the business relationship must be terminated.
In any case, you can easily perform your compliance checks and UBO checks from home with CDD On Demand. You simply only need to purchase credits and can then easily check your clients along different (sanction) lists. Don't forget to clearly document all the steps you are taking in the context of the client investigation. Your research should be replicable. Would you like more information about CDD On Demand products? Check out our pages about the compliance check, the UBO check and the monitor function.