Understanding 'Consider' Results in Your Client Due Diligence (CDD) Report
When conducting Client Due Diligence (CDD) through Legl's Engage platform, you may encounter a 'Consider' result in one or more sections of the report. This designation indicates that certain checks could not be fully verified and require further assessment. This guide outlines potential causes for 'Consider' results and suggests appropriate next steps.
My report has come back with a 'consider' result for one or more sections - what does this mean?
A 'Consider' result signifies that specific elements within a section of the CDD report were not conclusively verified. This may occur due to issues such as unverified addresses or unreadable identification documents. It's essential to evaluate these results in the context of your firm's risk-based approach.
Legl Assist: Generative AI CDD analysis and summary
Legl includes built-in Generative AI analysis tools that help summarize Client Due Diligence (CDD) reports—saving time and focusing attention on potential risks.
Legl Assist Highlights Three Areas:
KYC and AML: Identifies and highlights areas with Know Your Customer and Anti-Money Laundering relevance.
PEPs and Sanctions: Provides in-depth summaries of any hits found in these screenings, grouping and explaining their links to the client’s information.
Financial: Offers analysis of financial data returned in the check.
To view these insights, click "View summary" within the CDD report.
What are the different types of consider results?
Below is a summary of each of the four checks being completed and what could cause a "Consider" result, to help you make a decision on what extra due diligence may be required, if any. Law firms should have their own review and escalation process for their clients due diligence results as we are unable to provide legal advice.
You can also watch this video explainer on how to review the due diligence results.
Jump to section:
Identity Document Validation
Possible Causes:
Poor image quality: Blurry, faded, or damaged documents.
Unsupported formats: Temporary passports, expired IDs, or documents not using Roman characters.
Mismatch or error: Client-provided information differs from the document (e.g., nicknames or incorrect date of birth).
Compromised documents: The ID is flagged in police databases or is not genuine.
Example Next Steps:
Follow your firm's ID verification procedures.
Accept typos if risk is deemed low, and override the result.
Ask the client to:
Resubmit a clearer or different ID document.
Complete a video call for live verification.
Use the comments section to log due diligence performed or reasons for overriding the result.
Identity Validation
Legl checks identity using:
Credit agency data
Electoral roll data
Telephone databases
Mortality lists
Minimum Criteria for a "Clear" Result:
Not found on mortality lists AND
Match on name and date of birth AND
One or more matches on name and current address (across different sources)
Common Causes of "Consider":
Recently changed address
Typos in name or address
International address with limited data availability
You may choose to:
Accept ID document as proof of identity
Request an additional proof of address
"Unidentified results found" Result
If you receive a Consider result that reads "unidentified results found", this means that the technology has not been able to confirm that individual's data (e.g. DOB, name or address) against any of the databases or records used to perform the Identity Validation check.
This can be a common result for international addresses (due to limited datasets outside of the UK), but can also occur for some UK individuals (e.g. they recently moved address, or their information has simply not been found to be listed on the public data sources checked). As always, it is up to the firms risk based approach whether they are happy with the other documents provided in the report as a whole, or whether they prefer to ask for additional proof of identity documentation.
"N/A" Result
If Appendix 2 shows N/A, it's likely because the client’s address is outside the UK.
Legl can still verify international government-issued photo IDs.
However, address verification is limited due to data availability.
Clients will be asked to upload a proof of address, which you can manually assess.
Use the comments section to document any manual verification or override justification.
Biometrics
The report could be flagged "Consider" for one of the below reasons:
Image integrity: The quality and integrity of the uploaded files were not sufficient to perform a face comparison. (For example, the photo of the ID provided was a scan or the image is blurry)
Face detection error:
No face is found on the front of the document, no face is found on the selfie or video, or
Too many faces were found. If someone helped them complete the information this could have caused confusion with the technology.
No Liveness: At the biometric stage of the CDD the client is asked to make specific movements (e.g. turn your head from left to right). There maybe some basic movement from the client but they have not followed the specific instructions so the technology has flagged that this section of the checks should be considered
Source integrity: Selfie or video is found to be digitally tampered, from a fake webcam, emulator or from other dubious sources. This indicates a deliberate attempt at defrauding the system.
Face comparison: Face in the document does not match the face in the live photo.
Visual authenticity: Identifies whether the person in the selfie or video is real.
Spoofing detection: The selfie or video has been flagged as containing a face that is not real, also known as a "spoof". For example, a face on a piece of paper, a face on an identity document, a face on a digital screen, a screenshot, etc.
Example next steps:
Ask the client to redo the biometric check with clear instructions.
Consider verifying their ID via video call if repeat issues occur.
Document your decision and reasoning in the report.
Financial Checks
The report could be flagged "Consider" for one of the below reasons:
County court judgement: The individual has a court order registered against them for failure to repay a debt. This will detail the date of the order and the amount owed.
Debt collection check: The individual has had credit check(s) made against them by someone from a debt collection agency in the last 24 months.
No matching record: There was no record of the individual found in the credit agency lists.
Example next steps: Depending on your internal process, the type of service you are providing, and the risk profile defined within your firm, you may decide to follow some extra due diligence steps.
In the instance of "no matching record", you may request additional documents from the client to carry out further credit verification checks.
"N/A" Result: The CDD report will show Appendix 4: N/A when the client's address is outside of the United Kingdom. This is due to County Court Judgement information only being available for individuals in England, Wales, Northern Ireland and Scotland. Based on your agreed-upon internal process, you may choose to ask individuals with an address outside of the UK for additional documents to satisfy your Financial Check requirements.
PEPs and Sanctions (Watchlist Screening)
The individual could be flagged "Consider" if they are found to be on
Government and International Organisations Sanctions Lists
Proprietary database of Politically Exposed Persons, including family members and close associates of PEPs, covering high-ranking government officials in every ranking jurisdiction
Regional, national and international Law-enforcement and Regulatory Monitored Lists including Anti-Terrorism and Anti-Money Laundering watchlists (e.g. FBI Most Wanted and Interpol Wanted)
Proprietary dataset of companies and individuals subject to Adverse Media, monitoring thousands of news sources, business and trade journals, in addition to local, regional and national newspapers
Any individual found on the above lists that is a potential match for your client are presented for you to review.
Potential matches are in order of relevance. Results will be prioritised as follows:
Sanctions over other AML types
Exact name matches over inexact name matches
Date of Birth (DOB) match, over no DOB match
Country match over no country match or country mismatch
Primary and Secondary results
Results returned in the watchlist report are ordered according to relevance, and grouped into Primary and Secondary matches.
Primary matches are those that have returned the greatest relevance and have met 2 or more matches for the data provided in the search.
Secondary matches are results where less specific matches have been found.
🟠 Note: Due to variance in data across sources, it is not guaranteed that the most relevant results will always be listed first. You should always apply your own risk based approach when reviewing the results.
False positive matches
In some instances, the report may return a 'false positive' (someone with the same name that is not your client, for example). Where provided, the individual's middle name will be used to improve the accuracy of results. By ensuring that you have entered a middle name (where possible), this will help ensure a higher quality search and reduce the number of false positives being returned.
If you suspect the result to be a false positive you should follow the links provided in the results to qualify or disqualify the match. Paying close attention to the country of origin result, any images you can see and the timelines of the results.
Example next steps: If the client has a common name, it could be that the name referred to in a PEP or adverse media source may not be related to them. In this instance, check the timeline of the result and any further details included in the matches (e.g. date of birth or source country) to help you qualify false positives. Additionally, it is a good idea to follow the links included in the results and use additional details or photos of the matched individual to qualify false positives.
Documenting your review
Once you have made your assessment of each result you can mark each result with a ‘Yes’ or ‘No’ to confirm or dismiss it as a match for your client. You can also add individual comments on each result, to evidence the reason for your decision.
⬤ Note: Results marked with a ‘No’ will be removed from ongoing monitoring, reducing unnecessary monitoring alerts in the future.
Confirming or dismissing matches and documenting reason for decision:
The Watchlist review section provides you with a table listing all the potential matches for your client. Including their name, DOB and the data source they were found on (PEP, Sanction, etc).
If you are immediately able to determine a specific result is not your client, you can mark it with a ‘No’ in the left hand column.
If you require more information to make your assessment, or would like to add a comment documenting the reason for your decision, you can click on a given result to open a more detailed view.
This detailed view has more information about the potential matching individual, as well as the details of the Watchlists they have appeared on. At the bottom of the page you have the ability to mark the result with a ‘Yes’ or ‘No’ and add a comment.
All decisions and comments made will be added to the PDF report, once the entire report has been marked as ‘reviewed’.
If you need to escalate a specific result(s) you can add any comments and make any initial decisions, before escalating it to a member of your team following the steps below. All comments and decisions will be preserved for them to review.
If helpful, you can also view our how-to video walking through the Watchlist review process.
Escalating a "Consider" result
In most instances, "Consider" flags simply require you to review the report carefully, and potentially verify the data with your client. If your firm requires you to ask a colleague to review the report instead, you can assign a new Reviewer to the engage request from the 'review' window.
Click "change" and select the new reviewer from the drop down menu.
In some instances, you may need your client to complete the check again - if this is the case, simply click "Create Engage Request" and generate a new link for your client.