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Q1 “Video verification.”

  1. Can you explain why the passport photo is not adequate rather than just saying that it is not within the safe harbour?
  2. If we receive the KYC documents in question via email, and then the same documents are presented in the video call; Is this sufficient?
  3. The details of the presented documents are cross-checked live on the live video call.

JFSC SAY “Video verification.”

  1. The “safe harbours” are designed to indicate what may be considered “obtaining evidence of identity from a reliable and independent source”.
  2. While safe harbours are not mandatory, they set a clear line in the sand that indicates our expectations.
  3. Any alternative method needs to be demonstrably as effective and robust as the safe harbours.
  4. This will be difficult to demonstrate if the alternative method looks very similar to a safe harbour but lacks some of the key controls incorporated into the safe harbour.
  5. Obtaining a photo of a passport (or viewing a passport in a video call) clearly does not incorporate the controls that are set out in the safe harbours.
  6. Such methods would need further or alternative safeguards or controls to be considered equally effective.


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