In a modern version of the rogues’ gallery, HM Revenue and Customs recently posted a selection of photos of its twenty “Most Wanted” – you can see them here. The FBI in America has been doing this for years – on their Wanted page (“Be part of the solution”), they encourage people to report sightings of wanted terrorists, parental kidnappers, white collar criminals and more. They give lots of detail, from physical descriptions to aliases and several photos per person – it’s riveting reading. For instance, John Donald Cody (also known by thirteen other names, including the marvellous John J Ocean III) is wanted for questioning on espionage charges, sports a fetching array of hairpieces, and has a scar on his shoulder and is missing the tip of a finger. By comparison, the HMRC’s crew of tax evaders are a dull bunch – but they owe us £765 million and so we’d like a quick word, please.
One of the major stumbling blocks with verification of identity is photographic ID. No matter how often we stress it in training, some staff still seem happy to accept photocopied documents in which the photo is (a) microscopic, (b) blurred, (c) ancient, (d) too dark to decipher, or (e) all of the above. But when you think about it, the photo is one of the most vital pieces of CDD that you can collect. The name might be false, the date of birth optimistic, and the address non-existent in physical terms, but at least the photo should be fairly representative of the client as he was at the start of your relationship with him, giving investigators some idea of who they are looking for.
If I were an MLRO in an international institution, I’d think about printing out some posters of those HMRC and FBI wanted faces, and sticking them near the coffee machine – you never know who might look familiar over the mid-morning cappuccino and custard cream.
Hi Susan, I hope you’re well.
I’m looking for a bit of help with finding relevant rules, regs or guidance that states that copies of photographic id should have a clear and legible photograph for CDD purposes.
Can you help?
Sorry, Nick, I’ve checked my usual sources – JMLSG, GFSC, CCAB and Law Soc – but no joy. However, I think you would be on thin ice if your regulator pulled out a file and the photo was just a blob or blur… In the same way as it is expected that the words are legible on the copies you keep, I am sure that it is expected that the photos are decipherable.
Best wishes from Susan