According to a J.D. Power survey of banking customers in the United States (published March 2020) - roughly 55 percent of new bank account openings still take place at a branch. If there is one thing that the coronavirus as taught the banking industry - it is that the viability of the brick-and-mortar method of on-boarding customers (in-person) will not survive this pandemic.
In light of this - and in an effort of compassion, there is a trend developing where both regulatory bodies and working groups around the world are offering guidance to the covered institutions whom still rely heavily on manual Know-Your-Customer checks. In addition to the Financial Action Task Force guidance issued earlier this month (on Digital ID), supervisory authorities from the UK, India, Philippines, New Zealand and Australia have all cited some passable workarounds, including:
1. The use of electronic verification / digital identity platforms
2. The use of 3rd-party digital/managed KYC services
3. Verification through collaboration platforms (Skype, Zoom or FaceTime)
4. The use of electronic copies (scans or photographs) of documentation sent electronically for verification of identity
5. The infamous "selfie" (in conjunction) to other forms of identification shown in the same frame
6. The seldom used phone call to your customer
While some of these may be helpful, there are others that are clearly akin to taking on unnecessary risks that would not be acceptable under any other circumstance.
As the banking industry re-tools to retire some old ways of doing business - it will be interesting to see whether or not the core spirit and intent of KYC compliance are diminished along the way.
In a similar vein, the article linked below goes into a bit more about detail regarding the guidance being offered out of the United Kingdom.
For firms that are reliant on manual document checks for their Know Your Customer (KYC) and anti-money-laundering (AML) processes, this presents a major problem. Banks and other financial institutions – along with others affected by money laundering regulations (MLRs), such as lawyers, accountants and estate agents – all need to find a way to carry on performing these checks. As a result, the Financial Conduct Authority has felt the need to issue a ‘Dear CEO’ letter setting out ‘flexibility’ in its approach to KYC and AML for the duration of the current crisis.