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How can I ensure full compliance if I no longer collect identification documents from my customers?

The Bank Secrecy Act states that in order to perform the required “Customer Due Diligence” you must “verify” using documents or information obtained from a reliable source, that is independent of the person whose identity is being verified. While the BSA states that non-documentary methods are to be used as part of a client’s risk-based procedures outlined within your CIP to verify a customer’s identity. SmartSearch uses multiple independent data sources including Experian. All individuals are automatically screened against worldwide Sanction and PEP lists and enhanced due diligence is automatically triggered for any matches. Any false positives are removed - we only contact you if intervention is required - while our daily monitoring service ensures we are alerted if the status of any of your customers changes. The SmartSearch system is automatically updated in-line with any changes in regulation, so you can be confident you are fully compliant for the life of your contract.

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