AML/CFT/CPF Handbook
The information provided here is for general informational purposes only and is not intended to constitute legal or professional advice. It is provided 'as is' and should not be considered a substitute for a comprehensive review against the relevant laws and regulations as they apply to your company.
We developed our Verify by Tiller platform to provide regulated companies with the necessary information to meet the requirements of the JFSC AML/CFT/CPF Handbook.
To provide you with an additional layer of assurance, we engaged independent compliance experts, BDO Group Jersey, to review our Verify by Tiller platform's adherence to the handbook.
We're pleased to confirm that BDO's review found no gaps in our compliance.
We are happy to make BDO's report available to you via the request form below.
The Handbook and Verify by Tiller: An Overview
Does Verify by Tiller provide the information required under Article 3(2)(a) of the Money Laundering Order to perform customer due diligence
Yes. Verify by Tiller captures and where information required to verify the identity of an individual and were possible independently verifies that information from regulatory quality 3rd part data sources, and verified identity documents. Details are provided in the BDO report.
Is the use of independent data sources when obtaining evidence of identity acceptable
Whether they are acceptable is always subject to acceptance by the supervised person for their specific circumstances. However the JFSC AML/CFT Handbook [section 4.3.4, 66] confirms that a supervised person may demonstrate that it is satisfied that data or information it has accessed directly from data source(s) is sufficiently extensive, reliable and accurate under Article 3(2)(a) of the Money Laundering Order
Does Verify by Tiller apply additional eID measures to aid in the verifying the identity of a person remotely.
Yes, The JFSC AML/Guidance Notes specifically highlights features that eID applications may be used to mitigate the risk that documents have been tampered with or forged. Verify by Tiller employ numerous technologies to mitigate these risks including but not limited to:
Where the document type supports this capability (for example, passport document & ID cards), use of tamper proof NFC/RFID chips
Document tamper detection, verifying key documents markers against templated originals of that specific document and issue.
Image tamper detection and liveliness tests which where the document supports it image verification back to encrypted digital comply of image on NFC/RFID chips.
Full details are provided in the BDO report.
Does Verify by Tiller's screening/monitoring take into account the introduction of the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021
The main purpose of the Order is to give legal effect in Jersey to sanctions imposed by the United Nations Security Council (UNSC) and the autonomous sanctions regimes of the UK. This was necessary after the UK's departure from the European Union, as Jersey could no longer rely on EU sanctions regulations. This legislation, along with the Sanctions and Asset-Freezing (Jersey) Law 2019, provides the legal foundation for Jersey to implement a wide range of sanctions measures.
Verify by Tiller automatically checks individuals against the relevant UK and UN sanctions lists required under this order so is compliant. However it remains the responsibility of the supervised person that all requirements under this order are satisfied.
Does Verify by Tiller assist in the record keeping requirements set out in the Handbook
Business are required to keep accurate, clear and up to date records to satisfy customer due diligence and mitigate ongoing risk.
Verify by Tiller provides all the information it has captured, the checks and results of those checks and any supporting evidence such as images in one clear, simple but comprehensive PDF report that can be downloaded and included in the business records on the individual. Verify also provides an API with access to all the same information both in PDF format and in machine readable JSON format, allowing the CDD process to be fully integrated with your existing CRM or CLM system.
How does Verify by Tiller address the UK Global Irregular Migration and Trafficking in Persons (Sanctions) Regulations 2025?
The UK Global Irregular Migration and Trafficking in Persons (Sanctions) Regulations 2025 is a specific sanctions regime. It is the legislation that provides the legal authority to impose various sanctions, such as asset freezes, travel bans, and director disqualifications, on individuals and entities involved in people smuggling, human trafficking, or the instrumentalization of migration.
The names of people and entities designated as sanctioned under the Global Irregular Migration and Trafficking in Persons regulations will appear on the larger HMT Financial Sanctions List. This list, also known as the Consolidated List, is the list of people and entities who have been designated under various UK sanctions regimes including the Global Irregular Migration and Trafficking in Persons regulations as being sanctioned. This list is maintained by the Office of Financial Sanctions Implementation (OFSI) at HM Treasury.
The HMT Financial Sanctions List is one of the many sanction list that Verify by Tiller checks when performing individual or entity AML checks.
BDO Report on Verify by Tiller download Request Form
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