Prevention of money laundering and the financing of terrorism
Criteria for the use of an electronic provider
6.54 Before using a commercial agency for electronic verification, casino operators should be satisfied that information supplied by the verification provider is considered to be sufficiently extensive, reliable and accurate. This judgement may be assisted by considering whether the provider meets all the following criteria:
- it is recognised, through registration with the Information Commissioner’s Office, to store personal data
- it uses a range of positive information sources that can be called upon to link an applicant to both current and previous circumstances
- it accesses negative information sources, such as databases relating to identity fraud and deceased persons
- it accesses a wide range of alert data sources
- it has transparent processes that enable the operator to know what checks were carried out, what the results of these checks were, and what they mean in terms of how much certainty they give as to the identity of the subject.
6.55 In addition, a commercial agency should have processes that allow the enquirer to capture and store the information they used to verify identity.
6.56 It is important that the process of electronic verification meets a standard level of confirmation before it can be relied on. The standard level of confirmation, in circumstances that do not give rise to concern or uncertainty, is:
- one match on an individual’s full name, date of birth and current address
- a second match on an individual’s full name and either their current address or their date of birth.
6.57 Commercial agencies that provide electronic verification use various methods of displaying results – for example, by the number of documents checked, or through scoring mechanisms. Casino operators should ensure that they understand the basis of the system they use, in order to be satisfied that the sources of the underlying data meet the required standard.
Next chapter: Documentary evidence