• FC-1.4 FC-1.4 Enhanced Customer Due Diligence: Non face-to-face Business and New Technologies

    • FC-1.4.1

      Conventional bank licensees must establish specific procedures for verifying customer identity where no face-to-face contact takes place.

    • FC-1.4.2

      Where no face-to-face contact takes place, conventional bank licensees must take additional measures (to those specified in Section FC-1.2), in order to mitigate the potentially higher risk associated with such business. In particular, conventional bank licensees must take measures:

      (a) to ensure that the customer is the person they claim to be; and
      (b) to ensure that the address provided is genuinely the customer's.

    • FC-1.4.3

      There are a number of checks that can provide a conventional bank licensee with a reasonable degree of assurance as to the authenticity of the applicant. They include:

      (a) telephone contact with the applicant on an independently verified home or business number;
      (b) with the customer's consent, contacting an employer to confirm employment, via phone through a listed number or in writing; and
      (c) salary details appearing on recent bank statements.

    • FC-1.4.4

      Financial services provided via post, telephone or internet pose greater challenges for customer identification and AML/CFT purposes. Conventional bank licensees must establish procedures to prevent the misuse of technological developments in money laundering or terrorist financing schemes. Specifically, banks which provide significant electronic and internet banking services to their customers, should connect a programme to such systems to highlight all unusual transactions so as to enable the concerned bank to report such transactions. Conventional bank licensees must also ensure that they comply with any e-commerce laws and/or BMA regulations issued from time to time.