Managing risk in virtual client meetings

Another common issue is where clients have used middle names or changed their name on their ID documents without a lawful basis to do this (such as by deed poll or marriage certificate) – this should always be avoided.

The process involved with AML and identity checks should not be seen as a tick-box exercise. Ultimately, you need to be satisfied that the documents the client has provided are consistent with who they say they are.

We often come across clients who have very little or no valid proof of identity in their name for varying reasons, but what should we be doing with these clients? Should they be avoided altogether or is there an alternative way forward? 

We should be considering the range and type of evidence that a client can reasonably provide, as well as the reasons they have for not having more typical forms of documentation.

It may be that an individual risk assessment considering all factors in play may establish a genuine reason for the absence of expected documentation.

Virtual instruction-taking opens the doors to different risks and issues that may not have come into play face-to-face.

These considerations must be retained on file should it ever be questioned what sources of ID the client provided, why, and what investigations took place to determine their identity.

We need to be able to confirm why we consider a client to be of a certain risk level and why we consider the information we hold on them to be sufficient to satisfy our legal and professional obligations.

In summary, taking instructions virtually might seem like it is making life easier for everyone involved (which for the most part it is), however, virtual instruction-taking opens the doors to different risks and issues that may not have come into play had the instructions been taken face-to-face.

We must therefore make sure we are aware of these risks, and that we are managing them effectively to get the most out of virtual instruction-taking, which looks like it is here to stay.

Elizabeth Shimmell is client care team leader at Countrywide Tax and Trust Corporation; and Michael Hughes is a trainee solicitor at CTT Law