Following a short consultation with industry the Commission has today issued revised Annexes to the Financial Services Business ("FSB") and Prescribed Business ("PB") Handbooks on the use of technology in the customer due diligence process.
The updates have removed the guidance on the use of online utility bills and clarified further the interplay between the existing rules in the Handbooks and those in the Annexes relating to certification, e-certification and electronic verification.
In respect of the former, while there are inherent risks in solely relying on online utility bills, paragraphs 92/93 and 106/107 of the FSB and PB Handbooks respectively state that identification data does not have to be in paper form and that external electronic databases such as the internet, information published by government departments and subscription databases can be used. Accordingly, the evidential value of electronic checks should depend on the assessed risk of the business relationship or occasional transaction and it is for the FSB/PB to decide its risk appetite.
The revisions to the Annexes address in the short-term the feedback received from industry that the original guidance on the use of online utility bills was too restrictive. This issue will be incorporated into the Commission’s wider project to update the rules and guidance in the Handbooks in conjunction with revisions by the States of Guernsey to the Criminal Justice (Proceeds of Crime) Regulations.
For the avoidance of doubt no changes have been made to the main body of the Handbooks.