Relying on Digital ID for AML/CFT Purposes in Jersey and Guernsey

The financial services regulators in both Guernsey and Jersey have for several years officially recognised that regulated firms may, subject to appropriate safeguards, use electronic or digital means to meet their AML/CFT obligations to identify and verify the identities of their customers. This is in line with the position taken by the FATF – the intergovernmental body whose Recommendations are the accepted international standard on AML/CFT – and followed by many other regulators around the world.

In our experience, regulated firms in the Channel Islands have in large part continued to rely on traditional, paper-based means of verifying identity – but in the last few months, lockdowns imposed around the world in response to the Covid-19 pandemic have made it highly impractical or impossible to verify customers’ identities by such means, which has brought digital systems for identification and verification of identity into focus, and may well accelerate the transition from paper based to digital systems as the default means of verifying identity.

Click to view advisory

Matt SandersManaging PartnerT +44 (0) 1481 748
Rupert MorrisPartnerT +44 (0) 1481 748
Kate StoreyPartnerT +44 (0) 1481 748
Adam PickeringSenior AssociateT +44 (0) 1481 748

Jonathan HeaneyManaging PartnerT +44 (0)1534 700
Christopher ReedGroup Partner*T +44 (0) 1534 700
Leanne WallserGroup Partner*T +44 (0) 1534 700
Joseph Barker-Willis Senior AssociateT +44 (0) 1534 700 715
Tom FothergillSenior AssociateT +44 (0) 1534 700