JFSC said:- – CDD and VIDEO CERTIFICATION
06/12/2021
Q1 “Video verification.”
- Can you explain why the passport photo is not adequate rather than just saying that it is not within the safe harbour?
- If we receive the KYC documents in question via email, and then the same documents are presented in the video call; Is this sufficient?
- The details of the presented documents are cross-checked live on the live video call.
JFSC SAY “Video verification.”
- The “safe harbours” are designed to indicate what may be considered “obtaining evidence of identity from a reliable and independent source”.
- While safe harbours are not mandatory, they set a clear line in the sand that indicates our expectations.
- Any alternative method needs to be demonstrably as effective and robust as the safe harbours.
- This will be difficult to demonstrate if the alternative method looks very similar to a safe harbour but lacks some of the key controls incorporated into the safe harbour.
- Obtaining a photo of a passport (or viewing a passport in a video call) clearly does not incorporate the controls that are set out in the safe harbours.
- Such methods would need further or alternative safeguards or controls to be considered equally effective.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.