Jeremy has applied over the internet to open a bank account. Having established and verified Jeremy's identity by post, the bank can also do which one of the following, as an additional Customer Due Diligence measure?

• A. Ask Jeremy for a written reference.
• B. Ring Jeremy on a home or business number which has been verified by the bank.
• C. Undertake a Google search on Jeremy to seek confirmation of his identity.
• D. Wait 30 days before activating the account for Jeremy.

Answer: (A)

The main idea is strengthening identity verification through an independent check as part of Customer Due Diligence. After identity is established and verified by post, obtaining a written reference from someone who knows the customer provides third-party corroboration of who the customer is. This kind of written reference serves as credible, verifiable evidence from a trusted source, adding an extra layer beyond documents and self-declaration. It helps the bank satisfy regulatory expectations for verifying identity and screening for AML risks when opening an account online.

Relying on a phone call to a verified number can be useful, but it’s not as robust as a written reference because a phone line can be misdialed, spoofed, or recorded, and it may not provide the same level of independent verification. Conducting a Google search to confirm identity is inappropriate due to privacy concerns and the unreliability of public online information for identity verification. Waiting 30 days before activating the account doesn’t constitute an additional CDD measure and simply delays service without improving the accuracy of identity confirmation.