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
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.
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