For the most part, Engage checks completed by your clients will come back as "Clear" - indicating that no further action is required by you beyond reviewing the report provided.

To support firms as they take a risk-based approach to their clients, if Legl is unable to verify one or more elements in each section these will be marked as "Consider".

"Consider" means that one or more parts of the check have not been able to be completed - we may not be able to verify your client's address, or the ID document may not be readable by our system.

Legl has built in Generative AI analysis and summary tools to help the reader of the CDD report focus on the major aspects for consideration and reduce the time it takes to build a risk analysis.

Legl Assist for CDD reports focus on analysing three areas before creating an overall summary:

To view the summary you can click on the “View summary” button visible on the CDD check.

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.

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The main reason why a document may be flagged as 'consider' is that the document is not clear enough, either in the hard copy - with faded text or a damaged picture - or the picture of the document is not clear. Another reason why the document would cause a 'consider' result is the document not being one of a supported format: a document that is not a passport, driving license or national identity card using Roman characters or a temporary passport, one that is expired, or one belonging to someone under the age of 16. Finally, the document could be marked as 'consider' if the ID data does not match the information provided by the individual, is not a genuine document, or matches the police database for compromised documents.

The other reason this section of the report could be marked as 'consider' is if the client has entered different information to the personal data that appears on their ID document e,g they enter their nickname or make a mistake entering their date of birth.

The system will also check that the document they have uploaded is valid and in-date.

Example next steps: In all cases above you should follow your firms' internal process for verifying a clients ID. You can refer to the rest of the due diligence results to make a common sense, risk-based decision on what next steps you will take to complete due diligence on your client.

You may choose to ignore typos and override the consider result when marking the report as 'reviewed' or you may ask the client to complete a new Engage request. To mitigate the risks posed by a 'consider' result in this section, you may choose to ask for the client to present a different form of identification or verify the document via video call.

You can use the comments section to document the extra due diligence you have completed or the reason you are overriding the 'consider' result.

Legl utilises credit agency data, voting register data, and telephone database data alongside mortality lists to verify an individuals’ identity. The minimum criteria for a CLEAR result is:

Therefore, if the CDD report shows Appendix 2: Identity Verification as "consider" it may be a result of something small, like the client having recently moved house or countries, or typos in their name or address. Depending on your internal processes you may choose to accept the client’s ID document as a form of proof of identity or ask for an additional proof of address document.

"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 the CDD report shows Appendix 2: N/A it is most likely due to the client's address being outside of the United Kingdom. Our ID document verification is able to verify a government-issued photo ID document from any country, however, countries outside the United Kingdom typically have insufficient datasets for us to be able to reliably verify the individual's address. In these instances, we will be unable to provide a clear result for this section of the Engage report as no matches will have been found, however, the individual will have been asked to upload a hard copy proof of address document so you can manually verify the details they have provided at the top of the report.

You can use the comments section to document the extra due diligence you have completed or the reason you are overriding the 'consider' result.

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 detected: 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 on either. 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 say something specific out loud (e.g. a set of three numbers) and 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.

Example next steps: Depending on your relationship with the client, the type of service you are providing and the risk profile you may decide to follow some extra due diligence steps. In this instance, you may decide to verify the client via a video call or ask them to try the biometric check again or visit the office so you can verify them in person.

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.

The individual could be flagged "Consider" if they are found to be on

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:

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.

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.

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.

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.