In 2Shakes you can choose to verify the identity of your customers:
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:
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.
Use Electronic ID verification when:
Use Biometric + Electronic ID verification when:
Use Manual ID verification when:
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.
Electronic verification includes:
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.
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.
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.
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.
The AML Supervisors (DIA, FMA and Reserve Bank) have published a new explanatory note guideline for Part 3 of the Amended Identity Verification Code of Practice (IDVCOP). This update introduces some significant clarifications by the Supervisors, which we have discussed and confirmed with DIA.
The most significant change for 2Shakes users relates to clarifications around linking a person to the identity they claim.
Going forward, if you use the Standard Electronic IDV option in 2Shakes, you must also use additional methods to link the person to the identity they claim. Paragraph 19 of the updated Explanatory Note provides some examples of additional methods you may use. (We are in discussion with DIA around other options for additional methods which may be useful for some sectors – as soon as we have more on that we’ll let you know).
The 2Shakes Biometric + Electronic IDV option is very similar or the same as Example 2 in the DIA’s updated Explanatory Note, and satisfies the additional measures required. For this reason, the default ID Verification method in 2Shakes to Biometric + Electronic IDV.
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.
If you are unsure of any part of the process, or need further information, please either contact the organisation you are dealing with or email email@example.com.