Identity Verification

You decide when to use Electronic Identity Verification

Each eIDV you use costs $5 NZD per person (exc GST). With 2Shakes you only pay for the electronic Identity Verification (IDV) that you use. 2Shakes provides a step by step process that will help you decide:

1. Who the people are you need to Identity Verify
2. If you want to use electronic ID verification, or do ID verification manually yourself, or electronic IDV with addition manual identity verification measures.
3. If you will enter the ID details for the person, or if you will send an email link so they can enter their own ID details.

You are only billed for the people whose ID is electronically submitted for verification.

Only charged for what you use
We track the number of electronic ID verifications you do and charge you for them each month.  2Shakes connects with a third party AML ID expert provider.  We have secured discounted pricing which we can pass on to you.  Please note that you will still be charged if the ID verification fails to match. We get charged for each electronic ID that we submitted. So if the result is that the information fails to match you will still be charged.

How it works

Identity details are entered in the following fields:

Electronic verification includes:

• Name, Address and Date of Birth verification
• New Zealand Driver License Verification from the New Zealand Transport Authority (NZTA)
• New Zealand Passport Verification from the Department of Internal Affairs (DIA)
• International Watchlist / Politically Exposed Person (PEP) status sourcing

Information is verified via a third party bureau database to verify name, address and date of birth data. This database holds trusted source data on over 3 million NZ consumers, which is updated monthly by banks, finance and retail energy providers. Changes to the Credit Reporting Privacy Code have enabled this data to be used for AML/CFT verification purposes.

This service is focused on trusted source information which ensures that matched data is only confirmed based on the data being confirmed by a trusted source. This limits the opportunity for fraudulent applications passing the verification threshold. You should of course take appropriate legal advice regarding your AML/CFT identity verification compliance processes as part of the AML/CFT programme.

Obtaining Consent

The Credit Reporting Privacy Code 2004 governs who can disclose credit information for the purposes of undertaking identity verification in accordance with the AML/CFT legislation. Consent is required of the person whose identity you wish to verify.  If you have selected to send an email link to this person then they are asked to give their consent.  If you are entering ID details on their behalf, then you are required to confirm that you have their consent.

The personal information (name, DOB and address) entered is retained by Centrix who may use in the future for other reporting purposes, but only what is permitted under the Code (as per Rule 11). An access log of all disclosures including ID Verification checks is held so it is transparent to the individual if they request a copy of their own credit report in the future.

Enhanced CDD

If you have assessed that Enhanced Customer Due Diligence is required then your AML programme determines if and how you will undertake additional measures to confirm the Identity of a person. 2Shakes allows you to record the results of any additional steps you have undertaken and securely save any documents.

Enhanced Customer Due Diligence requires that you understand where your customers funds have come from. You can use 2Shakes to capture this and upload any documents that have helped you to verify the proof of wealth or source of funds.  Typically this might include legal documents, a sale an purchase agreement, bank or other financial statements, pay slips etc.

2Shakes can also help you gather this information from your customer.  If you have selected to send an email link to a person subject to Enhanced Customer Due Diligence then the system allows them to upload files or documents to 2Shakes at the same time as they complete their ID fields.  These files are uploaded to a secure location, which provides a secure alternative to emailing documents.

Identity when Signing

When you specify that Identity Verification is required from a person signing an agreement 2Shakes will require Identity to be verified when the agreement is signed.

IDV remotely via email

When someone is signing electronically remotely using a link from their email, and you have selected electronic identity verification then 2Shakes requires Proof of Identity, Date of Birth and Address details to be completed in the same screen, as the signing is completed.  In this screen the user also has the option to upload files if you have requested additional documents to be provided.

IDV in person via SMS

When someone signed electronicially in person using a SMS code sent to their mobile and you have selected electronic Identity verification then 2Shakes again asks for Proof of Identity, Date of Birth and Address details to be completed in the same screen, as the signing is completed.

Sign electronic with Manual IDV

If you have selected to manually complete IDV you can still get your agreement electronic signed.  Both remote (email) and inperson (SMS) methods will allow the agreement to be signed by your client. However only when you have manually confirmed IDV has been done in 2Shakes, will the agreement be considered signed (pending AML).

Identity when NOT Signing

AML/CFT requires the identities of all beneficial owners to be confirmed. This will often require you to confirm the identity of someone who is not signing the agreement.  For example a shareholder of a company is considered a beneficial owner, but would not be required to sign a contract for services with the company.

2Shakes helps you determine who needs to be identity verified.  It also allows you to specify that these people require IDV only.  Then you select how the ID verification will be done either electronically (via email link to person, or by you entering their details on behalf of the person), of if you want to manually complete ID verification.

Confirm when AML is complete

Legislation allows you to complete an agreement before AML/CFT is complete.  This means that it is okay to have some CDD outstanding on a signed agreement. Your AML programme just needs to specify how you will deal with these situations.  This allows you the ability to complete CDD and identity verification AFTER your agreement is in place. On a practical level this means that you don’t need to go to all the trouble and expense of fully completing all CDD for a client who may decide not to engage you.

2Shakes requires that you complete identity verification on your signing parties before the agreement is signed.  But you do not need to do identity verification for non-signing parties.

When all signing is complete the on an AML agreement it will change status to Signed (Pending AML).  Your AML compliance officer can use the agreements screen to filter for all agreements in the status of Signed (Pending AML). They can review these agreements and to confirm / complete all the requirements of your AML Programme. For example they may chase up / complete any ID verifications that are outstanding. They may add additional identity verification measures, they may review the risk assessment and ensure the nature and purpose statements are correct.  Once they are happy that everything is in order they use the AML complete button to change the status of the agreement to Complete.

Deciding to use electronic ID verification

Use electronic ID verification when:

• Someone has a digital presence that can be verified – Electronic ID verification matches the information provided against trusted external data sources.  Ideally the person would have a NZ passport or NZ drivers license. For address verification they ideally they would hold a NZ bank account, or be the account holder listed for a household utility bill, or be listed as the owner of a house.
• You want to avoid Identity Fraud – Using an electronic ID verification service allows you to verify details without holding a copy of the credentials.  This reduces the risk of personal details you hold being able to be inappropriately used for identity fraud.
• You want to save time & effort – Using an electronic solution makes the collection and verification quick and easy.  Manually collecting proof of address, doing online searches of sanction lists, doing PEP checks, storing evidence can all be time consuming.  All while delaying you getting to work for your client.

Use manual ID verification when:

• To strengthen electronic identity verification – When you consider that additional identity measure are required you can collect additional CDD evidence manually for a person.  For example:
  Additional Measures: if you feel that the risk is high, or if the CDD level is raised to enhanced CDD your AML programme may require that you undertake additional measures on top of electronic ID verification.  2Shakes enables you to record additional measures.
  Outstanding Verification: Electronic verification may not be able to fully verify the identity.  For example a persons passport might verify their name and date of birth, but because the person has recently moved the address may not match external records.  To complete CDD in this example you may manually verify the address and then use 2Shakes to record this using Notes & Files.
• Where you already know your customer – If you have already gathered sufficient evidence to confirm the identity of the person you can upload notes and files to record this to 2Shakes and then manually confirm that IDV has been completed.
• To avoid additional costs – If you want to avoid ID verification charges then you can verify the identity of a person manually.  You may like to refer to DIA’s Amended Identity Code of Practice which outlines a ‘safe harbor’ for how to do this.

Legislative Requirements

The Legal requirements reporting entities are required to meet to provide services in-scope for AML/CFT to customers are detailed in the Act.  In addition to this you can follow the Amended Identity Code of Practice.

2Shakes utilises a third party electronic identity ID service that is intended to assist users to comply with ID verification to meet AML/CFT. However it is up to your AML programme to determine if this service is sufficient on its own, or what additional measures will are appropriate for the situation and risk assessment of the customer. 2Shakes provides the ability for you to use Notes & Files to capture additional measures you have taken to confirm Identity.

Reports and Auditing

2Shakes records both the identity details as well as the results of electronic verification.  All notes and files you enter are also collated to allow you to report on all the CDD information collected.  When your AML compliance officer has consider and confirmed that the AML CDD is complete we create an AML report of all this data which is available for auditing purposes.

Find out more about AML in 2Shakes here.