Practice advice Q&As: May 2021
Our dedicated team of solicitors on the anti-money laundering helpline has been advising on anti-money laundering for over a decade. We can help answer enquiries around:
- customer due diligence
- source of funds
We can also help you navigate the Legal Sector Affinity Group (LSAG) anti-money laundering guidance for the legal sector.
The service operates Monday to Friday 9am to 5pm and you can call us on 020 7320 9544.
I act for the buyer in a conveyancing transaction. Due to COVID-19, the client is unable to attend our offices and I'll be taking instructions on a non-face-to-face basis. What electronic identification and verification methods could we use to assist with our customer due diligence?
As an alternative to face-to-face identification and verification, you may use electronic identification and verification (EID&V) where this is appropriate to the risks present in the transaction or the client’s profile.
Such methods may include:
- digital EID&V services that meet the requirements of regulation 28(19) of the Money Laundering Regulations 2017 – "secure from fraud and misuse and capable of providing an appropriate level of assurance that the person claiming a particular identity is in fact the person with that identity"
- gathering and analysing additional data to triangulate the evidence provided by the client, such as geolocation, internet protocol (IP) addresses, verifiable phone numbers
- verifying phone numbers, emails and/or physical addresses by sending codes to the client’s address to validate access to accounts
- using live and/or recorded digital video of the customer showing their face and original photo identification documents so that you can compare them to a scanned copy of the same document (for example, a passport or a driving licence)
For further information, see:
- LSAG advisory note: COVID-19 and preventing money laundering and terrorist financing in legal practices
- chapter 7.6 on digital ID certifications of the LSAG anti-money laundering guidance for the legal sector 2021
While every effort has been made to ensure the accuracy of the information in this article, it does not constitute legal advice and cannot be relied upon as such. The Law Society does not accept any responsibility for liabilities arising as a result of reliance upon the information given.
Have you got a practice question?
Call the Practice Advice Service on 020 7320 5675 or email firstname.lastname@example.org.
The Practice Advice Service is staffed Monday to Friday from 9am to 5pm.