The identification of a person and verification of person’s identity with information technology means take place according to the:
- procedure set out in section 31 of the Estonian Money Laundering and Terrorist Financing Prevention Act; and
- Regulation of the Minister of Finance “Requirements and procedure for identification of persons and verification of persons’ identity with information technology means”.
Identification of persons and verification of data does not obligate Fundy to establish a customer relationship or guarantee the accessibility of Fundy’s services.
The procedure of identification and data verification
Identification of persons and verification of data takes place in the following stages:
- Fundy verifies the person’s identity based on electronic ID or government-issued identification document copies.
- After successful identification, the person agrees with confirmations needed for continuing the session.
- Fundy verifies the data received in the course of identification.
- An interview is held in the course of which Fundy follows its principle of know-your-customer and identifies the circumstances of establishing a customer relationship or purpose of the transaction.
Fundy records all video meetings and preserves these recordings generally for five years unless some other term has been provided by law.
Fundy considers the identification of a person and verification of data to be unsuccessful if:
- the person has intentionally submitted data which do not match the data entered into the database of identity documents or other information or data obtained during the session;
- the session is interrupted or expires in the course of identification, survey, or interview if no operations have been performed for 15 minutes;
- the audio and image information flow does not meet certain minimum conditions;
- errors occur in Fundy’s information system during digital identification, digital signing, or recording of the session;
- the person does not give the required confirmations during the session;
- the person does not follow the directions of the advisor, e.g. does not remove headgear, face cover, or glasses, change the position of head or body, or show on camera the data on the document;
- the person uses assistance of another person without the permission of Fundy;
- circumstances which refer to suspected money laundering or terrorist financing are detected.
While establishing a customer relationship, if a person submits false, misleading or insufficient information, uses assistance of another person without the permission of Fundy, or does not follow the requirements specified by Fundy, we may refuse to establish a customer relationship with the person.