Overview
The Identity fraud screening section of your CDD report shows the results of five checks that use public and private sector data to assess whether the claimed identity may be linked to previous fraud or impersonation, belong to someone deceased, use compromised identity documents, or be synthetic.
This article explains what each result means and what you should do when a Consider result appears. The Identity fraud screening section is only available for firms on a DIATF-certified plan.
Where you will see this
The Identity fraud screening section appears in the CDD report generated after a client completes a Standard CDD or Enhanced CDD request. You can access the report from the Engage section of your Legl dashboard by opening the relevant request.
The section shows an overall Clear or Consider result alongside the other check areas in the report. Selecting the section reveals the individual result for each of the five sub-checks.
ℹ️ Further guidance
For an overview of all sections in the CDD report, see Understanding your CDD report.
What this means
Overall result
If all five sub-checks return Clear, the overall Identity fraud screening result is Clear. If any sub-check returns Consider, the overall result will show Consider and the relevant sub-check(s) will be flagged for your review within the section.
Individual sub-check results
Each of the five sub-checks runs independently and returns its own Clear or Consider result.
NSIRA – Fraud check
Clear: No fraud markers were found for this identity on the SIRA database.
Consider: Fraud markers were found for this identity on the SIRA database. The identity has been previously reported in connection with fraudulent activity.
NSIRA – Impersonation check
Clear: No impersonation markers were found for this identity on the SIRA database.
Consider: Impersonation markers were found for this identity on the SIRA database. The identity has been previously reported in connection with impersonation.
DDRI (Deceased Identity) check
Clear: This identity was not found on the deceased persons register.
Consider: This identity was found on the deceased persons register. The identity may be associated with a deceased individual.
Identity document fraud check
Clear: The supplied identity documents were not found on the police database of lost, stolen, or fraudulent identity documents.
Consider: The supplied identity documents were found on the police database of lost, stolen, or fraudulent identity documents.
Synthetic identity check
Clear: No evidence was found to suggest this is a synthetic identity.
Consider: Evidence was found to suggest this is a synthetic identity. The identity may have been fabricated or constructed rather than belonging to a real individual.
Common reasons you might see a Consider result
A Consider result can be returned by any of the five sub-checks. The reason depends on which check flagged.
NSIRA – Fraud or impersonation check: The SIRA database contains a record associating the identity with previous fraud or impersonation, submitted by member organisations including major UK banks and insurers.
DDRI (Deceased Identity) check: The identity matches a record on the deceased persons register. This may occur if the client shares a name and date of birth with a deceased individual, or where identity fraud using a deceased person's details is suspected.
Identity document fraud check: The identity document provided has been reported as lost, stolen, or fraudulent on the police database. This can occur even if the client is genuine and was unaware the document was compromised.
Synthetic identity check: The checks indicate the identity may have been constructed using fabricated or combined personal information rather than belonging to a real individual.
ℹ️ Important
A Consider result requires your review but is not a definitive finding of fraud or identity misuse. Your firm must evaluate the result in the context of your own risk policies and the specific sub-check that flagged.
What you need to do
If the result is Clear
No action is required. All five sub-checks returned Clear. Continue reviewing the other sections of the CDD report as usual.
If the result is Consider
Review the flagged sub-check(s) carefully before proceeding with onboarding. The specific sub-check that returned Consider is visible within the expanded section. Your firm's response will depend on your internal policies and which check flagged, but may include:
Requesting additional documentation or information from the client to clarify their identity or the documents they provided
Escalating to your MLRO or compliance officer before proceeding
Applying enhanced due diligence as part of your onboarding decision
Declining to act if the result cannot be satisfactorily explained within your firm's risk tolerance
What happens next
A Consider result does not automatically prevent the client from completing their request or block your firm from onboarding them. Legl flags the result for your review; the decision on how to proceed rests with your firm.
If you proceed with the client after a Consider result, you should document your decision and any additional steps taken in line with your firm's procedures and record-keeping obligations.
Important information
The Identity fraud screening section is only available for firms on a DIATF-certified plan. If you do not see this section in your CDD reports, your firm has not opted in to a certified plan.
Five sub-checks run independently within the section: NSIRA Fraud check, NSIRA Impersonation check, DDRI (Deceased Identity) check, Identity document fraud check, and Synthetic identity check. Each returns its own result.
A Consider result from any sub-check requires your review but is not a definitive finding of fraud. Your firm is responsible for applying its own risk-based approach when deciding how to proceed.
Legl cannot provide legal or compliance advice on how to act on a fraud check result. If you are unsure how to proceed, speak to your MLRO or compliance officer.