Anti-Money Laundering (AML)
KYC / KYB
Customer Due Diligence

Understanding the Meaning and Importance of KYB Checks

KYB, short for Know Your Business, is a due diligence process that focuses on verifying the identity and legitimacy of business entities. Just as Know Your Customer (KYC) procedures are employed to verify the identity of individuals, KYB checks help organisations assess the authenticity and trustworthiness of other businesses.

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Customer Due Diligence

The Complete Guide to PEPs and Sanctions

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Ben Lachenal

PEPs & Sanctions: The Complete Guide

As the world becomes increasingly globalised, businesses must navigate an array of AML PEPs and sanctions regulatory requirements. One such requirement is Anti-Money Laundering (AML) compliance, in particular the 6th Anti-Money Laundering directive, which involves identifying and verifying customers to prevent money laundering, terrorist financing, and other financial crimes. A key aspect of AML compliance is conducting checks on politically exposed persons (PEPs) and sanctions lists. In this blog, we will provide a guide to AML PEPs and sanctions checks.

What are PEPs?

Politically exposed persons (PEPs) are individuals who hold or have held a prominent public position or function, either domestically or abroad. Examples include heads of state, government officials, judges, and military officers. PEPs are at a higher risk of being involved in money laundering or other financial crimes because of their access to public resources and the potential for corruption. Therefore, it's essential to conduct due diligence on PEPs to ensure that they are not involved in any illegal activities.

It's also important to verify the identity of those associated with PEPs including family members and close associates. Not only are PEPs themselves at a higher risk of being subject or involved in money laundering and other financial crimes but those close to them could also be involved.

What are sanctions?

Sanctions are measures imposed by Governments, international organisations, or other bodies to restrict trade or financial transactions with certain individuals, organisations, or countries. Sanctions may be imposed for several reasons, including terrorism, human rights abuses, or weapons proliferation. Compliance with sanctions is crucial to prevent unwittingly supporting prohibited activities.

Since the conflict began between Russia and Ukraine in 2022, sanctions checking has become even more important for entities to conduct on their customers at the point of onboarding and through re-screening. Not only does sanctions checking form part of compliance requirements for regulated businesses, but it also protects the reputation of an organisation and provides a clearer view on their customer base.

What is a sanctions list?

Sanctions lists are often created to target entities that are believed to be involved in activities such as terrorism, human rights violations, or the development of weapons of mass destruction. The purpose of sanctions lists is to exert pressure on the targeted entities to change their behaviour or to punish them for their actions.

Within FullCircl's AML software, the following global lists apply:

Why are PEP and sanctions checks necessary?

PEP and sanctions checks are necessary for AML compliance. Companies must ensure that they do not conduct business with individuals or entities that are on a sanctions list or are considered high-risk PEPs. Failure to conduct these checks can result in hefty fines, reputational damage, and legal consequences.

How to conduct PEP and sanctions checks

There are several ways to conduct PEP and sanctions checks:

  1. Manual checks: Companies can conduct manual checks by searching publicly available databases, such as government and international organisation websites. While this method is relatively inexpensive, it can be time-consuming, may not be comprehensive, and there is always the risk of human error in this method.
  2. Automated checks: Companies can use automated solutions to conduct PEP and sanctions checks. Automated solutions use artificial intelligence and machine learning to screen databases and flag any matches. This method is more efficient than manual checks and can be integrated into the company’s existing systems.
  3. Third-party providers: Companies can also engage third-party providers to conduct PEP and sanctions checks. Third-party providers offer a range of solutions, from manual checks to fully automated systems. Using a third-party provider can be more expensive than conducting checks in-house, but it provides more comprehensive coverage and can also be integrated into existing systems.

How much PEP and sanctions information do I need to obtain?

How much information a business gathers on customers really depends on their risk appetite. FullCircl's Anti-Money Laundering (AML) solution splits these into three levels depending on how in depth the client wants to go within the check. All of these checks can be consumed through a single API integration.

Level 1: Senior Political Figures (SPF) List

  • Heads of state and high-ranking government figures around the world.

Level 2: PEP Select List

All the above plus:

Level 3: Watchlist (PEP, Sanction & Adverse Media)

All the above plus:

  • A much broader spectrum of civil servants, political party officials, senior members of the police force, city mayors, national NGO officials, political pressure and labour group officials.
  • Global law enforcement wanted lists.
  • Regulatory enforcement actions.
  • Global adverse media.
  • Global sanctions lists.

What to do if a match is found?

If a match is found during a PEP or sanctions check, companies must conduct further customer due diligence to determine if the individual or entity is indeed on a sanctions list or is a high-risk PEP. If the match is confirmed, companies must take appropriate action, such as freezing assets or terminating the business relationship.

By using orchestration platforms such as FullCircl's offering, businesses can conduct even more in depth checks on their customers which ranges from KYC software, address lookup, fraud prevention, and document verification to confirm a match or in the instance where a more comprehensive view of the customer is required.

PEP and sanctions checks are critical components of AML compliance and the importance of them will only continue to grow. Companies must ensure that they conduct these checks to prevent being involved in financial crimes inadvertently. Conducting checks manually, using automated solutions, or engaging third-party providers are some ways to conduct these checks. If a match is found, companies must conduct further due diligence and take appropriate action. By following these guidelines, companies can ensure that they remain compliant with AML regulations and protect themselves from financial and reputational damage.

If you require more information on how to effectively conduct PEPs and Sanctions, you can contact us here to book a demo.

Customer Lifecycle Intelligence

Vote FullCircl: Three big reasons (we think) FullCircl deserves your vote in the 2024 British Bank Awards

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Stuart Newton

FullCircl nominated for 
‘RegTech Partner of the Year’ in the British Bank Awards 2024

Voting has now opened for the British Bank Awards 2024. Run by Smart Money People, the British Bank Awards have been celebrating excellence in the banking industry since 2015.

FullCircl is proud to have been voted RegTech Partner of the Year in 2019, 2020 and 2023. So, why do we deserve your vote in 2024?

Continuing to drive the RegTech agenda

For us, it’s not a case of ‘won and done’.  We continue to set the pace for innovation in the RegTech market, shaping the future of compliance, risk management and financial crime prevention.  Since last year we’ve:

  • Acquired W2 Global Data Solutions to further enhance our expansive datasets and deep subject matter expertise in identity verification, through W2’s global KYC, AML, and anti-fraud services – opening up new consumer verification capabilities alongside our existing corporate entity screening.
  • Partnered with nCino to optimise time to funding for SME customers by reducing risk, removing friction and improving enhanced due diligence throughout the customer lifecycle.
  • Integrated with ComplyAdvantage to boost our PEPs, sanctions, adverse media and risk screening capabilities, delivering a highly-differentiated and dynamic approach to AML and risk management.

We have a highly-differentiated proposition

Not only are we unique in our ability to deliver both corporate and consumer compliance checks, but we also sit at a unique intersection of the market as a RegTech provider that also delivers a suite of revenue-boosting tools – tackling some of the most critical commercial and regulatory challenges through a single platform.

We help banks and financial service providers profitably identify and acquire, verify and onboard, and retain and grow customers.  Thanks to a range of Smart applications designed to solve specific commercial challenges, we’ve built a vision for the future of banking whereby every stage of the customer lifecycle – from the first engagement, through CDD and onboarding, to in-life customer care and perpertual eKYC – is augmented with the highest quality insight-driven intelligence.

  • Identify & acquire: advanced prospecting and sales intelligence
  • Verify & onboard: KYC and KYB compliance, Identity Verification, Fraud, AML and credit risk screening
  • Retain and grow: perpetual KYC/KYB, ongoing monitoring, customer retention and expansion intelligence

We’ve gone global

We can now identify millions of actionable insights on entities from 160 counties, providing a near real-time record of companies, their officers and shareholders, and importantly the relationships between them – vital in today’s complex and highly-nuanced regulatory environment.

We serve 700+ customers, process over 300 million onboarding and monitoring transactions per month and facilitate the onboarding of 200,000+ customers each year on their behalf.

Can we have your vote?

The British Bank Awards are voted for entirely by you.  It’s a chance to have your say and help us, as we continue to ease the burden on banks and provide cutting-edge solutions to help them grow by connecting the insights they need, when it matters most.

Vote for us here as RegTech Partner of the Year

Current Affairs

Companies House Rogue Filings Alert Highlights the Importance of Holistic KYC

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Stuart Newton

Warning on Rogue Filings at Companies House

Last week UK Finance, the banking trade association, issued a warning to banks regarding approximately 800 rogue filings relating to 190 companies that had been submitted to Companies House, apparently related to the discharging of erroneous satisfaction of registered charges.

This news comes at the same time as new laws come into force, as part of the Economic Crime and Corporate Transparency Act 2023, giving Companies House greater powers to query, reject, clarify, and remove incorrect information from the register.

Whilst the registrar is working to investigate the matter, and mitigate the risks, it has stated that these incorrect filings – saying a charge has been satisfied – remain valid and enforceable.

A holistic approach to KYB

For FullCircl, issues like this highlight the importance of a holistic approach to KYC/KYB and real-time screening of company data.  In addition to Companies House data (of which we deliver live updates to documents, including mortgages, charges, and debentures), FullCircl provides fast and easy access to comprehensive data on every company in the UK & Ireland – 250 billion data points from more than 40 sources (including credit reference agencies and a range of specialist data partners).

This can assist to not only validate firmographic data from Companies House, but deliver a broader, and deeper view of a company’s health. FullCircl users are also able to track their clients and receive notifications when a mortgage is satisfied, prompting further review if necessary.

FullCircl customers can rest assured that we are monitoring the situation to ensure that accurate information is provided via our suppliers. Get in touch with your account manager if you have any questions or concerns about the Companies House rogue filings.

Current Affairs

FullCircl + Acturis + BIBA Connecting the insights brokers need when it matters most

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Ashleigh Gwilliam

FullCircl + Acturis + BIBA - Connecting the insights brokers need, when it matters most

On 31st January 2024 we held an elite gathering of some of the UK's most influential insurance broking leaders. The setting for this auspicious event was the iconic NED, one of London's most exclusive member clubs.

We brought together experts from across the industry, from large brokers to independent regional firms, to talk about their biggest challenges - from onboarding speed and underwriting accuracy, to underinsurance, risk and fraud reduction, and meeting compliance duties. Not only were they treated to a slap-up lunch, but they also heard from five of the most innovative thinkers in the broking industry.

Kicking things off was our very own Andrew Yates.

A trifecta of digital broking excellence

Andrew talked about how FullCircl + Acturis + BIBA is a trifecta of success - taking the knowledge, guidance, and experience of BIBA, quantifying that into rules and data insights within FullCircl, and then surfacing them to generate meaningful opportunities for growth within Acturis.

The results being:

  • More accurate underwriting submissions, and therefore better premiums, terms and outcomes for clients.
  • Huge time savings and reduction in manual effort. Leaving brokers free to focus on what they do best - providing advice and service that supports and protects clients.
  • Better relationships for both clients and underwriters.
  • Improved compliance with the Consumer Duty - connecting insights and actions to deliver positive outcomes that protect clients from financial harm.

This was a great segue into the talk by Swati Chopra, Chief Information and Technology Officer at Partners&.

One version of the truth

Swati talked about why poor-quality data is the enemy of broking success - causing financial loss, operational efficiencies and increased workloads, compliance issues, and difficulties with analysis and reporting.

A key collaborator and the first broker to go live with the FullCircl SmartBroker + Acturis integration, Swati explained how having a single version of the truth, with high-quality reliable data and customer lifecycle intelligence saved them hundreds of hours in just a few months. She highlighted benefits including:

  • The ability to efficiently identify and win new customers.
  • Performing better due diligence and accelerating onboarding.
  • Improved in-life monitoring for better renewal rates.

Responding to industry shifts

A real highlight of the event was hearing from Acturis CEO Tony Goddard. His insights into the current and future trends of the industry were truly enlightening.

Speaking about his experience of the event, Tony said "The event was a great opportunity to network and discuss the real business value of the Acturis + FullCircl integration with our customers."

Tony highlighted how FullCircl + Acturis, two of the most recognisable technology partners within the insurance sector are helping brokers forge a new path in the digital era by revolutionising growth & client retention strategies. Formed in response to industry shifts, and built in collaboration with brokers, the partnership is helping brokers Identify & Acquire, Verify & Onboard, and Retain & Grow clients and prospects - ultimately connecting the insights they need, when it matters most.

Managing risk for growth and economic security

The luncheon was held just days after BIBA launched its 2024 manifesto 'Managing risk for growth and economic security'. We were therefore delighted that BIBA CEO Graeme Trudgill was able to join us.

As well as discussing his first few months as CEO, including a day one call from Michael Gove on the controversial subject of broker commission, Graeme talked about BIBA's recent research indicating that insurance broker regulation, particularly the Consumer Duty, has placed a disproportionate burden on the industry.

He also talked about tools such as SmartBroker are highly effective when it comes to assisting brokers to drive increased efficiency and reduced regulatory costs, which in turns creates more opportunities for growth.

Finally, we heard from David Sparkes, Regulation Director at BIBA.

A war cry

David ended the lunch with call to arms for brokers to push back when it comes to disproportionate regulatory demands. Explaining why, in its manifesto, BIBA has called for effective scrutiny of the FCA's growth and competitiveness objectives, as well as the scope of the Consumer Duty, he reaffirmed the themes of the day, and why connecting insights is vital if brokers are to continue to grow and flourish in the UK.

It's a game changer

If you'd like to learn more about FullCircl + Acturis + BIBA, then why not book a personal demo? Experience SmartBroker's capabilities first hand and explore how we can help you identify & acquire the right customers, verify & onboard them faster (while also assisting with Consumer Duty requirements), and retain and grow your existing portfolio whilst maximising revenue.

Want to join our next lunch?

Our invitation only lunch series is very popular but we're always keen to welcome new faces. If you're interested in joining the discussion, get in touch with us today.

Current Affairs

FullCircl responds to the launch of the BIBA Manifesto

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Ashleigh Gwilliam

FullCircl responds to the launch of the BIBA Manifesto

On January 10th, BIBA launched their 2024 Manifesto at the Houses of Parliament. FullCircl's newly promoted Director of Insurance Industry Growth, Ashleigh Gwilliam, shares his thoughts on what this means for the industry.

In this article:

  • Post-Covid-19 turbulence, inflation, Brexit uncertainties, and changes to consumer behaviour pose challenges for the UK economy.
  • BIBA has launched its 2024 Manifesto, highlighting the necessity for businesses to take risks for growth and economic recovery.
  • 45% of SMEs experienced increased insurance premiums, leading to reduced coverage, providing a unique opportunity for Brokers to advise on optimal coverage within budget constraints.
  • AON's recent survey identifies cash flow and liquidity as new top risks for UK organisations, reflecting the current economic situation.
  • BIBA calls for its members to "embrace technology" to "deliver excellent service".
  • Graeme Trudgill, BIBA Chief Executive to address senior figures at industry lunch hosted by FullCircl.

Turbulence in the UK Economy

Recent years have been turbulent to the UK economy. Following the Covid-19 Pandemic, we experienced high levels of inflation, uncertainties related to Brexit, supply chain disruptions, and shifts in consumer behaviour.

For the UK economy to fully recover, businesses need to take risks. Without risk, there is no growth. Insurance allows businesses to take risks, aligning with FullCircl's mission of helping businesses to better business faster, which is why I really welcome the 2024 BIBA Manifesto "Managing Risk for Growth and Economic Security".

The Crucial Role of Brokers in SME Insurance Amid Rising Premiums

The Manifesto references a survey by Premium Credit from October 2023 which uncovered that 45% of SMEs’ Insurance Premiums have increased, resulting in them reducing cover to reduce cost. This is an unfortunate fact but highlights the value brokers can add. When funds are limited, it is more important businesses receive a return on their investment; businesses are not insurance professionals, so taking the advice of a broker is essential to ensure you have the best cover possible within your budget. I commend BIBA for the steps they have taken in partnership with the ABI with their Signposting Agreement and access to the insurance committee to help drive individuals and businesses to organisations that can help them – particularly those in vulnerable positions. But, reflecting on the comments from my good friend Angela Irvine at Bletchley Group, it is important for brokers to demonstrate the value they are adding to the client journey, as it helps improve the industry’s overall reputation.

AON’s October 2023 Executive Risk Survey, also mentioned in the Manifesto, uncovered the Top 10 Risks facing UK Organisations, including a new addition to the list - Cash Flow and Liquidity, indicative of the current UK Economy. It is an issue many of our clients have discussed with us; feedback that contributed to our decision to launch our new SmartBroker service.  

FullCircl SmartBroker provides you with all the information you need to acquire new business & retain existing clients, prepare better underwriting submissions, and assist with compliance, aligned to the new consumer duty requirements; including key financial risk and liquidity information from Experian-powered credit data, adverse director history and CCJs – all designed to help brokers understand the financial situation at their clients. 2023 was also the year we announced our New BIBA Facility, allowing BIBA members access to our FullCircl SmartBroker service, with a 25% discount.

Navigating the Future: Initiatives for Tax Reform, Social Responsibility, and Climate Resilience

I commend the calls to reduce Insurance Premium Tax, ideally, I would like to see a complete removal of IPT on mandatory classes of insurance, for example employers’ liability, which would help fuel employment and economic growth. However, I understand this would be an impossible ask, as the tax revenue from personal motor insurance would be hard to replace.

I am also encouraged by the determination of BIBA, the ABI and DLUHC, to find resolution to the issues highlighted by the horrible tragedy at Grenfell tower. The Insurance industry’s primary concern should be to provide protection – particularly to those who need it most. This continues to be highlighted in BIBA’s Manifesto, with calls for improvement to categorising Cyber losses, dealing with new methods of construction, data sharing protocols regarding self-driving vehicles and personal property terrorism cover.

Is More Leniency Needed Towards Directors in Business?

Clarity surrounding Previous Insolvencies and County Court Judgments is long overdue. At FullCircl, we surface adverse director history and legal notices to our clients regarding the companies they are transacting with. A lack of a time-limit makes it difficult for brokers to provide advice to companies. Motor and Criminal convictions both have statute of limitations, why not insolvency? As a nation we except that people make mistakes, and certain crimes can be deemed ‘spent’, why are we stricter on directors taking chances in business?

Lessons from the Banking Sector

The Financial services and Markets act gives the FCA a secondary objective to fuel "growth and competitiveness" from the Financial services sector in the UK, yet the UK continues to have the second highest financial burden caused by regulation when compared to other leading jurisdictions.

BIBA calls for its members to “embrace technology” to “deliver excellent service”, calling out the value e-trade, claims management systems and improvements AI can bring through timesaving. While I commend this response, I would like to see further encouragement on the use of Data and Information. Lessons can be learned from the Banking Sector, who utilise the data to reduce manual effort and human error during the application stage. This tried and tested process can easily be replicated for the Insurance Industry. At FullCircl, we have assisted numerous multi-national banks by prepopulating business banking application forms, in one circumstance reducing the number of required answers from 80 down to just three. Not only does this improve the customer experience during the application process, but the increased accuracy could also minimise potential issues at point of claim; ensuring the right protection is in place when clients need it most.

Embracing Technology to Delivery Excellence in Insurance

This is why I am proud of our new partnership with Acturis. At the click of a button, brokers can enrich client files with data from over40 different sources, significantly reducing the time spent manually completing forms and removing potential for human error.

There is a plethora of data available to modern insurance brokers, the real key is finding the information that provides valuable insights, this is where our market leading Screening functionality can be so valuable. In seconds, FullCircl analyses all the information available, highlighting the key ‘golden nuggets’ that enable brokers to do better business, faster. This may include Adverse Director History, CCJs and PEPS & Sanctions, but also insights derived from company financials that identify a company’s demands and needs. It also assists with consumer duty requirements – for example, an increase in Export Turnover prompts a conversation regarding Marine Cover, Trade Credit requirements, and changes in PL & EL exposure, allowing you to deliver positive outcomes that protect clients from financial harm.

---

On January 31st, FullCircl, in partnership with BIBA and Acturis, are hosting an exclusive lunch for senior executives across the insurance industry. If you would like to learn more about our new SmartBroker service and Acturis integration, or hear more from BIBA CEO, Graeme Trudgill, regarding BIBA’s 2024 Manifesto, you can register your interest by emailing Robert Taylor.

Remaining spaces are limited and strictly limited to senior executives; therefore, unfortunately not all applicants will be accepted.

Identity Verification

“Smart eGate” Trial Imminent: Is this the beginning of the end for passports?

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Ben Lachenal

In this article:

  • UK planning 'Smart eGates' at airports, relying on facial recognition, eliminating the need for physical passports. Trials set for this year.
  • New eGates access biometric data remotely, making physical passports redundant.
  • Dubai Airport's 'Seamless Travel' and global trends align with the UK's move towards facial recognition in identity verification.
  • The UK experienced increased acceptance of remote identity verification, driven in part thanks to COVID-19. Over 60% of consumers are willing to use facial recognition for verification.

The Dawn of "Smart eGates": Revolutionizing Border Control

According to a story recently published by The Times, the UK will take its first step towards creating a truly “Intelligent Border” with the adoption of AI-driven ‘Smart eGates’ at airports.

Set to be trialled as early as this year, the units will negate the requirement for travellers entering the UK to present a physical passport, instead relying solely on Facial Recognition technology to confirm those crossing the border are who they say they are.

Global Trends: Biometrics Transforming Travel

The use of this technology is of course not entirely radical. Current airport eGates already take advantage of your biometrics, only they access them by decrypting the chip embedded within your passport before comparing the obtained data with a live image of you when you peer into the camera.

The newer, or should I say “Smarter” eGates, will instead access your biometric data remotely via a centralised database, rendering the physical passport surplus to requirements.

The UK isn’t alone. As well as in some Australian airports, Dubai International Airport will soon roll out ‘Seamless Travel’ for its residents, leaning on the reliability of Biometrics to enable residents to breeze through the tiresome immigration process “in as little as five seconds”.

Facial Recognition in the UK: From Everyday Life to Airports

Although the UK will not likely extend its use of Face Rec to the degree Dubai and other Middle Eastern countries intend to just yet, (soon you’ll be able to buy your duty-free using only your face!), this change in how we travel is really just an extension of how Identity Verification (IDV) using biometrics is already being embraced and trusted by UK citizens.

Facial Recognition – that is, the unique measurements between various points on your face – has been in use in the UK in various forms for a number of years already, and not just by the police. In fact, UK providers of IDV are some of the world’s leaders in this field.

Embracing Change: UK Consumer Attitudes and Industry Shifts

The Covid-19 pandemic illustrated how far UK providers of IDV tech had come along in recent years, with many of us using their technology to seamlessly confirm our identities remotely using Facial Recognition and biometrics when thrust into lengthy lockdowns. Even when stuck at home for months on end, not much was out of reach for UK consumers.

It’s no surprise then that the news of passport-less eGates will likely be seen positively across the country. Research suggests that as a nation, we’re embracing this exciting tech faster than any other: According to biometricupdate.com, over 60% of UK consumers have expressed a willingness to be verified in this way, and that’s growing significantly.

Closer to home at FullCircl, we’re also seeing the shift. We’ve witnessed first-hand many of our clients, including banks and major insurance providers, modernise and fortify their approach to onboarding by adopting document verification and facial recognition checks when dealing with customers remotely. You can read more about how we help businesses onboard customers here

It’s clear to see that as a nation, we’re already embracing Facial Recognition in our everyday lives, and we’re already enjoying the benefits it can bring. I believe extending this to the airport is a natural step, and one I believe the UK will not only welcome, but raise the standards in.

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