Customer identification under CARF builds on existing AML/KYC requirements while adding tax-specific elements. This guide covers the identification requirements CASPs must implement.

Identity Requirements

Individual Users

CASPs must collect and verify:

  • Full legal name (as appears on government ID)
  • Date of birth
  • Current residence address
  • Nationality
  • Government-issued identification number

Entity Users

For business customers:

  • Legal name and trading names
  • Registration number
  • Registered address
  • Principal place of business
  • Legal form (corporation, partnership, etc.)
  • Controlling persons (for certain entity types)

Verification Standards

Identification must be verified through reliable, independent sources:

  • Government-issued photo ID
  • Proof of address documents
  • Corporate registration documents
  • Electronic verification services
Electronic Verification

Many CASPs use electronic identity verification services that check government databases. These are generally acceptable under CARF, provided they meet local regulatory requirements.

Document Requirements

Acceptable ID Documents

  • Passport
  • National identity card
  • Driver's license (if photo and address included)
  • Residence permit

Proof of Address

  • Utility bills (recent, typically within 3 months)
  • Bank statements
  • Government correspondence
  • Tax documents

Entity Identification

Entity verification requires additional documents:

  • Certificate of incorporation
  • Articles of association
  • Register of directors and shareholders
  • Board resolution authorizing account opening
  • Identification of controlling persons

Ongoing Verification

Identification is not one-time:

  • Monitor for expired documents
  • Update information when changes occur
  • Periodic re-verification for high-risk users
  • Enhanced due diligence triggers
Document Expiration

Track document expiration dates and prompt users to provide updated documents before they expire. Expired documents may invalidate the self-certification.

Conclusion

Robust customer identification protects both CASPs and the integrity of the CARF reporting system. Integrate tax-specific requirements into existing KYC processes for efficiency.

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