AML / CFT document certification vs document verification

As a part of conducting customer due diligence under the AML / CFT Act 2009, most reporting entities follow the customer identity verification requirements prescribed by the respective product providers. These meet the requirements contained in the Amended Identity Verification Code of Practice 2013 (IVCOP 2013). Reporting entities can:

  • undertake document verification face-to-face with a client, or
  • rely on copies of the documents provided by the client, which have been certified by a trusted referee (as listed in the IVCOP 2013), or
  • undertake electronic verification of a client's name, date of birth and address, using credit check tools or identification check tools.

Face-to-face document verification occurs when the client presents an original document to a staff member of the reporting entity, the staff member photocopies that document, and then confirms in writing that the copy is an exact replica of the original.

However, when some reporting entities attest documents obtained from clients in a face-to-face situation, they incorrectly use the word ‘certify’ in the attestation wording. Typically the attestation wording is along the lines below:

“I hereby certify that this is a true and correct copy of the original document."

The IVCOP 2013 states that only trusted referees can undertake document certification. Trusted referees are those individuals who hold certain occupations prescribed by the IVCOP 2013 (for example a Justice of the Peace, Notary Public, registered medical doctor, registered teacher, MPs, etc. Please refer to the IVCOP 2013 for a full list of trusted referees.) It is likely some reporting entity staff members may also hold certain occupations prescribed by the IVCOP 2013, however when undertaking face-to-face document verification for AML / CFT purposes, staff members holding the above occupations should not use the word ‘certify’ but use the suggested wording, because these staff members are involved in the transactions.

Solution

To meet the requirements of the IVCOP 2013, avoid the use of the word ‘certify’ when attesting documents. Below are two suggested wordings:

1. I have sighted the original and confirm that this is a true copy.

<Staff member name>
<Name of reporting entity>
I have sighted the original and confirm this is a true copy.
<Signature of Jack Saw>
Jack Saw 
Jack Saw Ltd
6 January 2018.

2. I have sighted the original and verify that this is a true copy.

<Staff member name>
<Name of reporting entity>
I have sighted the original and verify that this is a true copy.
<Signature of Jack Saw>
Jack Saw 
Jack Saw Ltd
6 January 2018.

If you are using the word ‘certify’ when undertaking face-to-face document verification then you should immediately change to using one of the sample formats above.

For further information please contact us.