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PAY-176 Payments & Banking

What can know-your-customer records prove?

Know-your-customer records can show the identity information and documents used to open, verify or maintain an exchange or financial account.

Avoid the dangerous assumption

The dangerous assumption is that successful verification proves the named person personally controlled every later transaction.

Records may include name, date of birth, address, identity documents, facial images, verification checks, phone number, email address and source-of-funds information.

They can help identify the customer relationship accepted by the provider.

They may also show when verification occurred and what information was supplied.

But the account may later be shared, sold, rented, compromised or operated by another person.

Identity documents can be stolen, altered or used under deception.

A genuine person may also knowingly open an account for someone else.

Provider verification methods and confidence levels vary. The provider may have checked document authenticity, facial similarity, database information or only selected account details.

Do not describe a know-your-customer record as proving exclusive account control.

Use login history, devices, sessions, IP addresses, authentication events, communications and transaction behaviour to assess who used the account.

Compare the verification material with other evidence and identify inconsistencies.

Where facial verification or document checks are involved, establish what the provider actually checked rather than assuming a forensic identity examination occurred.

Preserve the complete provider record, decision outcome, timestamps and any later re-verification or account changes.

When reporting, distinguish the verified customer identity from the person proven to have accessed and operated the account.

Operational takeaway

Use know-your-customer records to establish the provider’s registered customer relationship, then prove transaction control separately through access, device and contextual evidence.

Keep moving

Where this question leads

These links explain why the next page may matter, rather than presenting an undifferentiated list.