Ask for the evidence that fits.
The document step is designed around the document presented. Capture the relevant passport page, or the sides needed for an identity card or driving licence. The request should make clear which pages or sides your client needs to provide.
The selfie step connects the person completing the journey to the identity document. Address evidence can be requested separately when it is needed for the case.
A photograph is only the starting point.
Reading a name from a document is data extraction. Establishing that the document is reliable and belongs to the person presenting it is a separate verification task. A selfie comparison alone should not be described as proof of liveness.
AMLCode is designed to show the outcome of each identity check alongside the supporting evidence, including results that need your firm’s review.
Leave room for a different route.
A client may struggle to photograph a document, use a camera or provide standard evidence. Your firm should have an alternative process for clients who cannot complete the online steps.
HMRC recognises that documentary evidence varies. The firm needs an evidence policy and a reasoned approach to cases that do not fit its usual requirements.
HMRC: documentary evidenceDoes UK AML law require every client to send a selfie?
The core obligation is to identify and verify the customer. A document-and-selfie flow is one approach to remote verification; it is not a universal statutory sequence for every customer.