The Department of Internal Affairs advice to ADLS is as follows.

March 2020 – Response received from Department of Internal Affairs to the ADLS Property Law Committee’s Query concerning AML customer due diligence in view of COVID-19 published, as follows:

If a reporting entity is unable to conduct customer due diligence (CDD) because the customer or client is in self-isolation due to Covid-19, then the following points should be considered in dealing with the situation:

• A reporting entity may trigger exception handling procedures provided that the customer demonstrates that they are unable to comply with the requirements under Part 1 or Part 2 of the Amended Identity Verification Code of Practice (IVCOP) 2013 (click here).
• Reporting entities are recommended to document the customer's circumstances.
• It is possible for a customer to be verified through electronic identity verifications (Part 3 of IVCOP).
• Reporting entities may complete delayed verification (under section 16(3) of the Anti-Money Laundering and Countering Financing of Terrorism Act 2009) provided the following two criteria are met:

1. Verification of identity is completed as soon as practicable; and
2. ML/TF risks must be effectively managed through procedures of transaction limitations and account monitoring or through other appropriate risk management procedures.