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Guidance on remote ID and verification

Non face-to-face identification and verification

Use of video conferencing to assist with the identification and verification process. If sending personal or sensitive information supporting identity verification by email or other electronic means, the Client should consider taking additional steps to mitigate security risks, including, where appropriate, encryption. To undertake manual identification and verification, please follow this process:

1. The client should send a clear, legible colour image of the photo page of their passport / ID document using a suitably secure means, such as encrypted email.

2. During the video call with the client, he or she should hold the passport / ID document alongside their face. By checking the digital copy along with capturing the image of the client with the passport / ID document, the Notary needs to be satisfied that they are one and the same before proceeding

3. In addition to the passport / ID document, the client should provide to the Notary a digital copy of their valid proof(s) of address (such as driving licence, utility bill , bank statement etc)

4. The Notary reserves the right to request additional documents and third party validation in support of these revised identification and verification measures, and to manage the risk in his sole discretion.

Should the client and / or matter in question raise additional red flags and present a higher risk of money laundering, the Notary will ensure that he is satisfied that those risks are addressed before proceeding. This may include obtaining further verification of identity or undertaking other measures as stipulated under r.33 (5) of the Money Laundering Regulations 2017

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