Overview
Some CDD results contain signals that indicate an identity requires closer scrutiny before your firm reaches a decision. These signals do not mean a client is fraudulent, but they do mean your firm should apply enhanced care before proceeding.
Legl surfaces three categories of higher-risk signal in your CDD results. This guide explains what each one looks like and what to do when you encounter it.
What this covers
Consider results, including component-level breakdowns showing where verification fell short
Fraud flags returned by Legl's identity verification providers
Prior CDD check history for an existing contact
How this works
Consider results
When a CDD check returns a Consider result, Legl provides a breakdown of the specific checks that could not be fully verified. This breakdown is visible in the CDD report in Legl and in the downloadable PDF.
A Consider result means confidence in the identity could not be established to the required standard. Your firm should treat any identity returned with a Consider result as requiring enhanced scrutiny, and apply appropriate due diligence before deciding how to proceed.
ℹ️ Further guidance
For a full breakdown of what causes a Consider result and what to do next:
Fraud flags
Some CDD results include fraud signals returned directly by Legl's identity verification providers. These include:
SIRA fraud database hits: the identity has been linked to confirmed fraud in financial institutions
Amberhill matches: the identity or document appears on the UK Metropolitan Police National Fraud Database
Compromised document signals: a document has been reported as lost or stolen
Where any of these signals appears in a CDD result, your firm should treat it as a high-risk indicator and escalate in line with your internal AML and risk policies. Do not proceed without senior review.
ℹ️ Important
Fraud database signals such as Amberhill hits are serious indicators. Your firm's MLRO should be consulted before making a decision on how to proceed.
Prior CDD history
All previous CDD checks for a contact are stored in Legl and visible on the contact overview page. Before initiating a new CDD check for an existing contact, you should review their prior check history.
If a previous check within the last 24 months returned a Consider result, a fraud flag, or a verification failure, treat the new check as higher-risk and apply enhanced scrutiny accordingly.
When you would use this
When reviewing a CDD report that has returned a Consider result
When a CDD result contains a fraud database flag or fraud signal
Before creating a new Engage request for a contact who has previously completed CDD with your firm
Key things to be aware of
Consider results require your firm's review but do not mean a client has failed CDD. You must decide the appropriate course of action using your risk-based approach
Fraud signals such as Amberhill hits are high-severity indicators that should be escalated in line with your internal policies
Legl does not make compliance decisions on behalf of your firm. It is your firm's responsibility to determine the appropriate next steps when higher-risk signals are present
Your firm's MLRO should be consulted where you are unsure how to proceed
Where to find this in Legl
CDD report results and fraud signals: the Engage section of your Legl dashboard, within the relevant Engage request
Prior CDD history: open the relevant contact record from the Contacts page to view all previous checks