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Timetable For project completion
The timetable to complete each risk group was stated on 15th July 2002 as:
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High risk Customers – to be identified within 12 months
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Medium risk customers within 24 months
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Low risk customers by the end of 2004, with possible slippage to August 2005.
Identification levels according to risk grouping
For the 'Current Customer Review' the degree of diligence required to re-identify customers is dependent on procedures currently adopted for establishing customer identity, and the risk within each customers' account or the product line. This means that
different levels of processing (across different portfolios of customers and between different banking organisations) will be required to comply with this initiative. The FSA have indicated the absolute minimum and the maximum requirements to be:
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The minimum level of re-identification would involve a validity check against the
current ER
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The maximum would involve a procedure enabling financial service institutions to re-identify their existing customers to the level of diligence set out in the JMLSG Guidance Notes for new customers. In short, the solution should be
compliant with the following:
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No single document or source of data can be used to establish identity
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As an alternative or supplementary to documentary evidence of the identity and address, the applicant's identity, address and other information may be checked electronically by accessing one or more data sources
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True full name and/or names used and current permanent address, including postcode should be independently validated for all private individuals whose identity needs to be verified
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A risk based approach as to what is reasonable in the circumstances can be adopted when obtaining satisfactory evidence of the identity
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Procedures should exist to guard against impersonations, invented identities and the use of false addresses.. If the application is non-face to face, one or more additional measures should be undertaken
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