Certification and remote verification

The Firm's preferred approach is to obtain identity verification through its approved electronic verification systems and other primary verification measures set out in the applicable Client Due Diligence Checklist.

However, there may be circumstances where certified copies of documents or remote verification measures are appropriate.

Certification is intended to provide additional comfort that a document is a true copy of the original. It is not, by itself, proof that the information contained within the document is accurate or that the person presenting it is the genuine holder of that document.

When considering certified documents, lawyers should remain alert to:

• fraud and impersonation risks;
• alterations or manipulation of documents;
• inconsistencies between documents and other information obtained;
• unusual certification arrangements; and
• any other circumstances giving rise to concern.

Remote verification may be appropriate where permitted by the Firm's procedures and Client Due Diligence Checklists. In such circumstances, lawyers should consider whether the verification measures adopted are sufficient in light of the level of risk presented by the client and matter.

Where you verify identification remotely, you must follow the current remote-verification procedure. This will ordinarily require you to:

1. obtain a clear copy of the identification document before the call;
2. ask the individual to show the original document during a live video call;
3. compare the copy with the original and the photograph with the individual appearing on screen;
4. ask the individual to turn the document over, move it and, where relevant, show other pages so that you can assess whether an original document is being presented;
5. record that you saw the original during the call and whether you identified any inconsistency or concern; and
6. send the copy and your confirmation to the Clients Team for review and central retention.

Remote inspection should not be used where there is any unresolved doubt concerning the individual, the document or the reliability of the process. In those circumstances, alternative verification or in-person certification should be obtained.

The detailed requirements relating to certification, electronic verification, remote verification, acceptable certifiers, document standards and evidential requirements are set out in the current Client Due Diligence Checklists and associated guidance.

The responsible lawyer should not focus solely on whether the documentary requirements have been satisfied. The objective remains to understand who the client is, who owns or controls them, who is authorised to instruct and why it is reasonable for Keystone to act.

Where there is doubt regarding the reliability of documents, the identity of an individual or the adequacy of verification measures, additional enquiries should be undertaken and guidance sought where appropriate. A document certified by another professional must be transmitted and assessed in accordance with the current CDD Checklist. The regulated status, identity and authority of the certifier must be capable of verification, and the certification must not be accepted where its authenticity or reliability is in doubt.