COVID-19 has given rise to unusual circumstances and new AML/CTF challenges for firms. Firms are reminded to ensure that whilst operating within the legislative framework, they are satisfied that their policies, procedures and processes continue to reflect their risk based approach, including any temporary adjustments required for COVID-19.
The FCA’s statement in this regard is at https://www.fca.org.uk/firms/financial-crime/financial-crime-systems-controls-during-coronavirus-situation.
COVID-19 lockdown is likely to disrupt the administration of documents used for identification and verification. Firms should consider whether policies and procedures need to be adapted to take this into account, having been risk assessed and documented accordingly. See for example https://www.gov.uk/government/news/drivers-granted-7-month-photocard-licence-extension relating to the extension of the validity of photocard drivers’ licences.