On 30 April, an article from Dentons says that many firms are exploring undertaking electronic due diligence to verify customer identities. This necessity it says was recognised by the FCA in its “Dear CEO” letter of 31 March, aimed at firms providing services to retail investors. This made it clear that, while the FCA would entertain some flexibility, firms were nonetheless expected to continue operating within the FCA rules and in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The article looks at how the identity verification might be undertaken, including the use of third-party providers.  It concludes that while careful thought is required to ensure that the provisions put in place are adequate and meet the requirements of the MLR 2017. Nonetheless, as with many other things, it appears that electronic verification may become the “new normal”, even after we emerge from the current crisis.


If you’d like to help to contribute to the cost of the new laptop and desktop I have had to acquire, now that I am 5,000 miles away from my originals –



Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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