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Customer Due Diligence

Customer due diligence (CDD) is not something which should be the responsibility of the customer, even though it sounds that way. In fact, the diligence is on the part of a bank or other financial institution (FI); it’s up to them to be diligent about who they are taking on as a new account holder.

This may seem like common sense, but the risks of not carrying out CDD are huge in today’s online environment. In the ongoing arms race between fraudsters and legitimate business, slacking on CDD can cost any vulnerable company dearly; it may even mean bankruptcy for some.

Due diligence vs. verification

When a potential customer applies for a new account online (as opposed to walking into a bank), all FIs carry out identity verification checks. These will be a multi-step process, starting with official documentation to verify identity, a separate address check, possible corroboration by a selfie, and a “liveness” test to ensure a physical person is there filling out the online form.

With CDD, however, this is just the start of the process. Once satisfied that an applicant is real, and who they say they are, a raft of other checks need to be carried out. These are to ensure that the person concerned represents a low enough risk for the FI to take on.

A range of databases will be accessed, from governmental to international, private and public, searching for any flags against the verified customer’s name. Most names will produce no flags, but some will represent a risk of some kind; it’s then up to the FI how to proceed.

CDD and the time factor

Low risk customers can be onboarded within a matter of hours; liveness checks and selfies make this process quick and painless. However, a customer who is flagged in any way will necessitate further checks. These can take 48 to 72 hours to complete, which is an awfully long time in today’s instantaneous culture.

For the FI, the risks of these delays have to be taken into consideration. Firstly, banks and FIs want customers; and friction of any kind when onboarding is a sure-fire way of losing potential customers. Doing the numbers, a FI must consider whether the numbers of customers they lose (even higher risk ones) is more detrimental than the possible losses through fraud.

Also, if an applicant is genuinely dangerous financially, the longer the verification process goes on, the more likely they are to wonder what the checks are finding. In this case, they may decide to regroup and refine their application, including what ID and financial history they have in place.

The benefits of automation

For both customers and FIs alike, the more automated the CDD process can be made, the better. After initial verification, a well-designed and thorough system of database searches, particularly if employing AI, can allow the business some leeway to continue the process, while the customer experiences little or no friction.

Even when a business relationship is formed, effective CDD will carry on working behind the scenes; flags may appear after enrolment, and transaction patterns can be monitored for any suspicious behaviour, as defined by ever-upgraded and agreed standards.

Age Verification

Any parent knows that more children are accessing the internet, more regularly and in more ways, and younger than ever before; this is a trend which is only likely to continue. As education and youth health providers turn to the web to offer services seen by society as positive, those which pedal less wholesome fayre are waiting to reap the rewards.

Illegal vs. Harmful

As well as being a living nightmare for most parents, the likelihood of children accidentally or deliberately accessing websites, goods and services which could harm them is something governments are starting to take seriously. What parents and governments want is some form of age verification which blocks underage users from accessing illegal or harmful sites.

Illegal is, in some ways, easier to police. The fact is that it is illegal to sell or offer a range of goods and services to anyone under a certain age; in this case, websites which do face a hefty fine, or possible closure.

Harmful, meanwhile, is less straightforward. Businesses which sell fireworks, for example, know that their products can harm children; however, those which offer certain services can at least claim a lack of evidence. Any harm done to minors from viewing unsuitable images is much harder to prove than a burn from a firework.

Interested parties

How seriously online businesses take age verification, sadly, often depends on their own self-interest. It is simply not in the interests of, say, a dating site to make every visitor verify their age; this interrupts the flow of registration, and will result in a drastically reduced conversion rate. At the end of the day, this is seen as being bad for business.

One way around this is a badge system, whereby a user looking for a date will – at least in theory – prefer someone with an age-verification badge than someone without. This level of light-touch internet policing is something that regulatory authorities like the UK’s Ofcom are looking at. The dangers of pushback by internet providers must be weighed against the likelihood of minors suffering harm at the hands of adults because of half-hearted age verification processes.

Non-anonymous age verification

Even in age restricted areas of the market, not all businesses take age verification seriously. A recent survey showed that only about half of these employed robust methods; the other half relied on anonymous verification, including self-assessment and verification by scanned documents.

A serious age verification system is one which requires the user to give up some of their anonymity. This should really involve a photograph, which in today’s world could just mean a selfie. The image of someone’s face popping up as part of an application or registration is still one of the safest means of age verification.

Although some will say that this goes against the spirit of the internet, parents and authorities such as Ofcom have more pressing concerns to worry about. In an increasingly web-reliant world, protecting minors from harm still falls to responsible adults; robust age verification is one tool to help in this ongoing struggle.

The FinTech Revolution Will Likely be Missed Out by Those With Debt Problems

UK, 13th February 2020: Analysis of StepChange Debt Charity’s clientele has disclosed new insights regarding the financial behaviour of people making steps towards debt recovery.

A study conducted by Experian revealed that 88% are very engaged with the online world, however a significant 40%, are unlikely to be managing their finances digitally. StepChange Debt Charity has recognised the potential of the latest online tools that may facilitate individuals build financial resilience and get over their previous debt problems.

The majority of the people surveyed were found to be online enthusiasts. Mainly from lower income households, they’re active social media users and are probably high users of digital entertainment services, like gaming and video streaming websites, however a lot less likely to interact with FinTech tools – along with online banking services.

Age was identified to be the largest influencer of digital engagement. 14% of StepChange Debt Charity clientele were those with young families. Of all the groups, these were the ones who were found to be the most likely to employ the use of online banking, as well as digital cash management tools.

In comparison, around 12% of clientele were found to be older individuals and retirees. This group is the least likely to use online financial management tools and don’t have very much interest in accessing these services digitally.

Digital money-management tools are able to facilitate individuals in difficulty, to avoid wasting money and gain a framework for money management, which may facilitate them to avoid or perhaps reduce the impact a financial crisis could have.

Experian and StepChange Debt Charity will continue to work alongside each other to offer even more insights, building more understanding of ever ongoing challenges, and look upon potential solutions of how clientele can gain higher autonomy of their finances. The charity is close to launching a brand-new online hub to assist individuals with persistent credit card debt.

Although it is not claimed that online tools can solve the nation’s debt problems, they are able to assist, and there is also a potential for an array of new services which can better engage people who are financially insecure.

Seeing as most people who find themselves in debt, are in this situation because of a change in their circumstances, helping those to manage their money and also build financial resilience, means they are much more likely to be in a position where they are able to weather tougher times if and when they occur.

It would also be easy to assume that we are all using digital technology in the same way and at the same consumption rate. However, we’ve discovered that this simply isn’t the case.

FinTech tools are changing the way that many of us are managing our money. However, it is apparent from our findings that a considerable amount of individuals looking for assistance with debt issues, are reluctant to use online financial tools, this will pose interesting challenges for the debt advice society and sector at large.

Become Data Driven by Overcoming Obstacles

To quote the well-known rhyme, “water, water all everywhere, nor any drop to drink.” I feel can also be true of data. Where organisations have a lot more data than ever before, only a few are able to take advantage of this resource and truly leverage it for insight.

There are no doubts regarding the value of data. It’s viewed as a key competitive advantage, and in some instances, a strategic asset financially.

However, translating your data into a meaningful insight may be a very different task to storing and managing it, from a regulatory perspective. we have seen a large number of businesses invest in many kinds of data initiatives, like analytics, machine learning automation, customer insight, data governance, etc. Yet, most businesses still report that they’re not sufficiently data driven.

Every year we conduct a world study of data management practices and of data usage. This year, we surveyed over a thousand practitioners regarding how they would like to leverage data. The research looked into a number of the obstacles that faced them and why only a few manage to leverage data for insight. we noticed that 3 key areas emerged.

Firstly, there’s a sizeable degree of distrust when it comes to information. The standard professional observing data doesn’t know how the data got there, what state it’s in, or even when it’s useful. Whereas the knowledge that data gives you may result in better insight and more informed decision making, a large level of distrust usually causes leaders to fall back on making their choices by gut instinct, instead of by knowledge that has been provided via the use of data. Subsequently, we’ve consistently witnessed over the past years that many believe that nearly one third of their data is not accurate.

Secondly, we are seeing the rising levels of data debt. Data debt is much like technical debt. You’ve got data assets that may not be fit for purpose, or have data that consists of a high level of inaccuracy. Unless you’re taking the time to repair that data, and govern it properly, you’ll forever have a suboptimal data operation. In turn, poor quality means that several businesses aren’t totally seeing the ROI or expected advantages in a number of the investments they’re making.

Finally, there’s a skills shortage when it comes to data. This doesn’t simply mean professionals, like data analysts, data scientists, and chief data officers (CDOs). There’s a general lack of understanding across the board around data, within the broader business. We’ve seen a growing number of businesses talking about facilitating a wider usage of data across their business and looking to do a lot more with data insight, however only a few people across organisations are actually data literate. Our survey results indicated that most businesses have reported that literacy of data has to become a core ability of staff over the next 5 years.

To generate the amount of insight required to leverage data fully, as a valuable asset, organisations will be required to tackle problems around its accuracy, trust, and of course, data skills. Unless these elements are addressed, organisations will remain surrounded by all of this useful data that will not provide the business with what it actually needs.

6 Ways to Protect Your Data

As a small business owner, it is always important to consider data security.
When looking at data you may store virtually, from customer’s private information, to financial records, it’s not difficult to see that a breach would quite possibly result in serious damage to your business.

One of the board members at the National Cyber Security Alliance, along with the Vulnerability Research Team’s Senior Director for cybersecurity provider Sourcefire, were consulted to find out what security measures were key for small businesses.

1. Establish strong passwords

The simplest thing to do in order to strengthen your security, is implementing strong passwords.

A simple tip for creating hard-to-crack passwords, is to use combinations of capital and lower-case letters, numbers & symbols, and to make them 8 to 12 characters long.

It is advised to avoid using your birthdate, or anything personal to you.
Use a checker to see if you have crafted a strong password, change your password at least every 90 days, and never write it down!

Another key aspect is to make sure each user has their own login credentials, never use one username and password for all.

2. Put up a strong firewall

Firewalls are an essential aspect of protecting your network, they protect your network by policing the traffic that comes in and goes out. Firewalls are a standard practice when it comes to network security.

3. Install antivirus protection

Another standard practice is anti-virus & anti-malware software, these are the last line of defence, should you be breached. It is always wise to choose an anti-virus & anti-malware software that you trust, and that’s right for you.

4. Update your programs regularly

Ensuring that your programs are regularly updated is vital in the ongoing endeavour of being fully protected. There’s not much value in installing all this fancy software, if you’re not planning to maintain it.

It’s essential to update regularly as the goalposts are constantly moving, and while no security application is 100% fool-proof, it keeps your system up-to-date with the latest protection available!

5. Secure your laptops

Laptops are at a much higher risk of being lost or stolen, this is an obvious fact due to their portable nature. Because of this, taking extra steps in order to protect your sensitive data is important.

One of the simplest things to do is: encrypt your laptop! What encryption software does is, alter the way information looks on your hard drive, so unless you have the correct password, it can’t be read.

Another simple but very effective way of protecting your laptop, is to not leave your laptop anywhere where it may be an easy target for opportunists. Preventing your laptop falling in to the wrong hands may save you, your business and your clients, a lot of unwanted aggravation.

6. Educate your employees

Prevention is definitely the best approach when it comes to the security of your data. Make sure your employees understand the importance of safety, when it comes to navigating the internet. They should understand the potential security risks they may put upon the company, if they decide to make bad decisions online.

5 Key Background Checks Employers Need to Make

For a great number of employers, screening the backgrounds of their potential employees is a must. Screening can be complex and challenging, especially when HR, as well as hiring managers are unsure how to stay absolutely compliant.

Currently, 60% of organisations in the UK conduct background screenings, according to the statistics provided by Sterling Talent Solutions.
This percentage is said to increase year on year as employers are becoming more aware of its importance.

Compliance appears to be the top reason employers are carrying out these checks, however, keeping up-to-date with the ever-changing regulations can be challenging. So, the question is, how can employers stay legal when it comes to the screening process?

Criminal Record Checks

Criminal record checks that are carried out by employers must be proportionate and also relevant to the employee’s position in question, it is also to be in compliance with The Police Act (1997) and the Rehabilitation of Offenders Act (ROA) (1974).

According to employment law associates, employers are allowed to ask applicants about their criminal record, however, the ROA (1974) restricts to what extent an employer is able to base their decisions using such information.

In the case of “Spent convictions” – where a crime has been committed previously, but no re-offence during a given period, employers should not request information. These applicants are treated as having clean records, unless there is an exception that applies under the ROA (1974).

Credit Checks

Credit checks are an element of screening that is used, particularly in the financial sector. Like criminal record checks, they are to be proportionate to the job at hand. For a role like a financial director, a credit check will be necessary, however a job that doesn’t require any financial responsibilities wouldn’t likely need a credit check.

It is recommended by The Information Commissioner’s Office (ICO) that credit checks are to be conducted only when a less intrusive option is not available.

Social Media Screening

With checking platforms like Facebook & Instagram, you are able to capture applicant’s activities that may be potentially incriminating. There are however legal risks and consequences if you get it wrong.

The primary issue is, if the job applicant claims that a decision to not employ them was based on information found by the employer, from one of their social media accounts.

Education & Credential Verifications

Checking an applicant’s qualifications and credentials can give you a clear understanding of their knowledge, specialties and skill sets.

Some candidates may however be tempted to fabricate the results of an educational & credential verifications check, via the use of technology, which can obviously affect the reliability of these kinds of checks.

Reference checks

One of the best ways to ensure that you are hiring the right person, is a reference check. It is advised however that certain rules are adhered to, such as making sure discriminatory questions are avoided.

Recruiters should be vigilant, as acting on a reference that is potentially discriminatory may cause issues, as they may be liable for damages/loss of earnings, if the offer is withdrawn due to a reference of this nature.

UK’s Credit Score Will be Protected During The COVID-19 Pandemic

In the UK, on the 31st March 2020: The 3 major credit reference agencies (CRAs), Experian, Equifax and TransUnion have, today, confirmed that all of consumer credit scores are protected once agreed ‘payment holidays’ have been put in to place, as a result of the COVID-19 pandemic.

Payment holidays are agreements made between individuals and their lenders, to pause regular loan payments. Earlier this month the UK government declared that homeowners affected by the crisis are able to request a payment vacation of up to three months (this includes both residential and buy-to-let mortgage customers).

To help individuals who require payment holidays, a special measure known as “emergency payment freeze” is currently being implementing by the CRAs. This ensures that everyone’s current credit score is protected for the length of the agreement payment holiday.

In conjunction with government guidance on mortgages, lenders could also be ready to create special arrangements across different kinds of credit, which could include payment holidays, reduced payments, paused payments or credit limits being increased. These special arrangements are all covered by the CRA emergency payment freeze agreement, this means that any impact to your credit score will be minimised.

How Will a Payment Freeze be Reflected on My Credit Report?

If you and your lender have agreed on an emergency payment freeze, then during this time that your payments are paused (with that lender) the payment status of your account will not get worse. for instance, if your account was up up to date prior to the freeze beginning, your account can will still show as up to date up until the freeze ends. If you were already behind with payments, the amount of arrears before the freeze began will continue for the length of the freeze. Throughout the freeze, the monthly payment amount shown on your report will remain the same.

Will The Payment Freeze be Recorded Anywhere on My Credit Report?

No, the fact that a payment freeze was agreed with your lender, won’t be recorded on those accounts or anywhere on your credit report.

How will a payment freeze affect my credit score?

Agreeing with your lenders to pause payments for a set time shouldn’t lead to payments showing up as being defaulted on your credit report, this should mean that your credit score won’t be affected. Please bear in mind that, in addition to the payment status of your accounts, credit scores additionally factor in other elements, like your total level of unsecured debt (for example, the balance of any credit cards, personal loans and overdrafts) and how heavily you use your credit cards (your credit utilisation).

Could the payment freeze impact my ability to get credit in the future?

Under the Emergency Payment Freeze agreement, an individual’s credit score will be frozen or maintained during the agreed payment holiday period. CRAs cannot guarantee that payment holidays won’t impact a consumer’s ability to obtain credit in the future, as different lenders policies will invariably be different. This should ideally be discussed with your lender directly.

What if I fall behind with payments without an agreed payment holiday in place?

If a customer falls behind with their payments without a payment freeze, then the standard CRA position applies – a worsening status is probably going to mean that your credit file is negatively impacted, which is why it’s necessary to have early discussions with your lender if you’re thinking that you might have difficulty meeting any of your repayments.

I tried to call my lender but couldn’t get through. Could I just cancel my Direct Debit?

Until you’ve discussed your circumstances with lenders, attempt to keep making your regular payments if you are able to. It is strongly discouraged to pause payments, for instance by cancelling Direct Debits, while no agreements have been made with your lenders. Unauthorised missed payments aren’t good for credit scores and will also have an effect on your ability of obtaining credit in the future. Banks, lenders, along with other providers are understandably busy attempting to assist their customers during this tumultuous time. To help, many mortgage lenders have recently updated their websites to permit customers to pause their payments online.

COVID-19’s Impact on The UK Economy

KPMG forecasts a decline of UK GDP by 2.6% for 2020, this is on the condition that the COVID-19 pandemic will be contained by the summer, with a predicted sharp recovery during the first half of 2021 as uncertainties that surround the dissipate.

If an even more enduring outbreak would occur, it may prompt a decline of 5.4% this year. Business investment would be particularly hard hit, along with consumer spending, due to COVID-19 related uncertainty and disruptions.
KPMG offer a flat growth forecast for the second half of this year, but also offer a forecast of a sharp recovery in the first half of 2021, with a 1.7% UK GDP growth in 2021.

A contraction of 2.6% in the UK economy during 2020 is expected, due to the impact of the COVID-19 virus, this is according to KPMG UK’s most recent quarterly economic outlook, however a more protracted outbreak may result in perhaps, a more severe effect than the experienced downturn in 2008-2009. In the case of either scenario, the economy is expected to recover at the latest, by the second half of 2021.

The main scenario that KPMG has offered assumes that the measures put in place for public health will stem the rising number of cases by summer.
If this is the case, then the expectations are that the economy will remain flat in the latter half of the year, and will have a strong recovery moving into the first half of 2021, as the uncertainties around the pandemic dispel.
This will see UK GDP decrease by 2.6% this year, but then grow by 1.7% in 2021. However, in the case where the pandemic persists up until the latter half of next year, GDP may contract by 5.4% this year, then a further 1.4% in 2021.

More action will be needed to shore up the UK economy

With recent measures announced by the Chancellor, the significant disruption to economic activity during the first half of the year may see unemployment peak at a relatively low figure of around 5.6% entering May.
KPMG’s predictions are that it will gradually ease to around 4.1% by Q1 of 2021, which will leave the labour market relatively tight once again.
The protection of jobs and incomes will provide in the short term, much needed support of the besieged households of the UK.

Due to the recent quarantine measures, which includes the restrictions on social gatherings, businesses that sell consumer goods and services, are set to face a significant fall in demand. The disruption in the supply chain, as well as loss of workforce and workplace shutdown, will challenge importers and exporters all at the same time, as UK’s key trading partners also head towards a recession. A low inflation, however, may leave the Bank of England room for monetary expansion in order to combat both economic downturn and the turbulence in markets, but with record low interest rates, measures of more creative stimulus will need to be used.

COVID-19, Social Distancing and It’s Impact on The DBS ID Verification Procedure


Due to the outbreak of Covid-19, also known as the Coronavirus, we have all recently witnessed our way of life rapidly change.

The global economy has been significantly affected, people are worried about their security, we are exercising social distancing, and as a nation, doing what we can to stop the further spread of the Coronavirus.

What is Social Distancing?

Social distancing is exactly that, distancing ourselves from all unnecessary social interactions. We have been advised by the government to stay at home, to avoid any crowds, and to keep a distance of at least 2 meters if we do come into contact with others.

Pubs, clubs and restaurants have been asked to close in order to keep the public from congregating and being in close proximity to one another. Many other non-essential retail shops have also been asked to closed their doors in support of social distancing and aiding in curbing the spread of COVID-19.

Why is Social Distancing so Important?

Social distancing is important because it slows down the spread of the Coronavirus, this slowing down of the spread, also known as flattening the curve, will help to alleviate the NHS from being overwhelmed.
Flattening the curve ensures that those who need hospital care will get it, and as a result, many lives will be saved.

Stopping The Spread

As the virus is so contagious and can be transferred so easily, it is imperative that we make sure we frequently wash our hands, disinfect and clean all surfaces at home. We need to also refrain from social interactions, arrange for your shopping to be delivered if you can, and do not share towels, toothbrushes or utensils with anyone, including members of your family. 60
If we can implement all these precautionary actions, we give ourselves the best chance of a swift recovery.

What Changes Have Been Made to The DBS ID Verification Procedure as a Result of Social Distancing?

In order to support the government’s efforts, there will be temporary changes to the way DBS ID Verification procedures will be conducted.

As it stands, the best practice for validating ID documentation is to carry out a face-to-face examination, however if this is not possible, there is the option of conducting a live video call as an alternative.

Current guidance stipulates that the ID checker must physically possess the original documents, in order for them to be thoroughly checked for any possible indicators of fraud.

Seeing as the public have been advised to not travel, and to work from home when possible, there have been significant difficulties in receiving the physical documentation, which in turn is delaying applications, and in some cases has prevented applications from being submitted.

In order to ensure that the DBS is able to carry out the necessary checks at this time, ID documents are now to be viewed over a video link, and scanned images used prior to the submission of the DBS check.

However, when the applicant first attends their position, they will be required to provide original copies of their documents. These changes came into effect on Thursday 19th March 2020.

The Importance of the Electoral Roll

Recruiters have moved on from simply looking at CVs, screening application forms and asking tricky questions at interview. 21st century recruiters and interviewers have a whole host of tools at their disposal to screen candidates applying for jobs. Generally, jobs which have a higher degree of responsibility, or where the wrong candidate could cause serious financial damage have higher levels of checking. Employers might look at social media accounts, speak to previous employers, check with universities about degree qualifications or ask you to bring your passport to prove your identity. In the financial service industry, credit checks are common and basic identity checks extend to many other industries too. If that’s the case for your new job, the electoral roll takes on a lot more significance.

What is the Electoral Roll?

The electoral roll, also known as the electoral register, is an official list of everyone registered to vote in the UK. Local boards around the UK send out letters usually every year to each household, asking someone to complete the details of all people over the age of 16 living there. The information on the electoral roll is used to produce the little voting cards which drop through the door every time there’s an election. The electoral roll used to be a physical paper register, but it is now held digitally.

Why is it Important?

The electoral roll is one of the first things that any identity checking service will look for. Someone who is not on the electoral roll has less of a digital “footprint” and therefore won’t be able to apply for credit, loans or take out a mortgage. If you’re not on the Electoral Roll this will have an ongoing impact on your credit history and without utility bills and similar in your own name, proving your identity can be tricky. People who move around a lot, such as students, are less likely to be on the electoral roll.

Getting on the Electoral Roll

If you’re not on the electoral roll, and are eligible to vote in the UK, then the good news is that registration is very straightforward. Search online for “register to vote” and follow the link on the official government website. Once you’ve registered, you don’t need to go back and re-register for each subsequent election. As the electoral roll is a public document, once you’re listed on the roll, you’ll appear on the databases which the credit reference agencies and identity checking services use.

Credit Checks and Pre-Employment Screening

Not all employers run credit checks on their prospective workers. It is however standard for people working in banks, insurance companies and in other organisations where workers have access to money or could be influenced to commit fraud. Employers aren’t expecting a candidate to have no debt whatsoever, it’s more about weeding out people who have such serious financial problems that they may be tempted to commit fraud. Many employers repeat the check every year or two years, to make sure that someone’s financial circumstances haven’t changed.