CAMS · Question #231
Which measure to mitigate risk does the Basel Committee's Customer Due Diligence Principles suggest banks apply when accepting business from non-face-to-face customers?
The correct answer is A. Certification of documents presented. The Basel Committee's Customer Due Diligence for Banks paper recommends requiring certification of documents as a compensating control for the heightened risk posed by non-face-to-face customer relationships.
Question
Which measure to mitigate risk does the Basel Committee's Customer Due Diligence Principles suggest banks apply when accepting business from non-face-to-face customers?
Options
- ACertification of documents presented
- BRequiring an in person interview with the customer
- CImposing a limit on permissible account activity for a defined period of time
- DRequiring additional review of account opening documents by senior management
How the community answered
(45 responses)- A80% (36)
- B2% (1)
- C11% (5)
- D7% (3)
Why each option
The Basel Committee's Customer Due Diligence for Banks paper recommends requiring certification of documents as a compensating control for the heightened risk posed by non-face-to-face customer relationships.
The Basel Committee's CDD principles explicitly identify certification of documents presented by the customer as one of the specific measures banks should apply when physical identity verification is not possible in a non-face-to-face onboarding scenario. This measure compensates for the inability to inspect original documents in person and helps maintain the integrity of the KYC process.
Requiring an in-person interview is contradictory for a non-face-to-face customer relationship and is not a recommended compensating measure under the Basel Committee's CDD guidance.
Imposing limits on account activity is a transaction monitoring control applied after account opening, not a document verification measure specifically recommended by the Basel Committee for non-face-to-face onboarding.
Additional senior management review of account opening documents is not listed in the Basel Committee's CDD principles as a primary recommended mitigation for the non-face-to-face customer risk scenario.
Concept tested: Basel Committee CDD measures for non-face-to-face customers
Source: https://www.bis.org/publ/bcbs85.htm
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