Guernsey Revises Client Due Diligence Guidelines
by Jason Gorringe, Lowtax.net, London
11 July, 2016
The Guernsey Financial Services Commission has revised the annexes to its "Handbook for Financial Services Businesses" and "Handbook for Legal Professionals, Accountants and Estate Agents" on the use of technology in the customer due diligence process.
The updates have removed the guidance on the use of online utility bills and clarified the interplay between the existing rules in the Handbooks and those in the Annexes relating to certification, e-certification, and electronic verification.
The revisions address feedback received from industry that the original guidance on the use of online utility bills was too restrictive.
While the Commission said that it recognizes that there are inherent risks in solely relying on online utility bills, the Handbooks state that identification data does not have to be in paper form and that external electronic databases such as the internet, information published by government departments, and subscription databases can be used.
The Commission says that the evidential value of electronic checks should depend on the assessed risk of the business relationship or occasional transaction and it is for the financial services business or prescribed business to decide its risk appetite.
This issue will be incorporated into the Commission's wider project to update the rules and guidance in the Handbooks in conjunction with revisions by Guernsey's legislature to the Criminal Justice (Proceeds of Crime) Regulations.
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