What to Do When a Client Cannot Complete Identity Verification

Introduction

Occasionally, a client may be unable to complete electronic identity verification despite multiple attempts and clear guidance. This can be due to technology limitations, accessibility issues, or document constraints. Knowing how to handle these situations — while maintaining your compliance obligations — is important for both client service and regulatory standing.

Common Reasons a Client Cannot Complete Verification

1. No supported identity document: The client does not possess a passport, driver’s licence, or provincial photo ID card. Some clients may only have expired documents, non-photo health cards, or foreign documents not recognized by the platform.

2. Device limitations: The client does not have a smartphone or tablet with a functioning camera, or their device is too old to support the verification application.

3. Accessibility barriers: Clients with certain disabilities may have difficulty with selfie capture, liveness detection prompts, or small-screen interfaces.

4. Connectivity issues: Clients in remote areas may lack the stable internet connection required to upload document images and complete real-time biometric checks.

5. Persistent technical failures: Despite meeting all requirements, some clients experience repeated failures due to edge-case combinations of lighting, device, and document conditions.

Resolution Options

1. Offer alternative document types: If the client has a valid government-issued photo ID from another jurisdiction that the platform can process, guide them to use it.

2. In-person verification: FINTRAC permits in-person identity verification using a government-issued photo ID. If electronic verification is not feasible, arrange for the client to present their document in person at your office or a designated location.

3. Dual-process verification: FINTRAC also permits verification by confirming a client’s identity through two independent, reliable sources — such as a credit bureau report and a government registry. This method does not require the client to photograph their document.

4. Agent-assisted verification: Some platforms support a mode where a trained staff member can guide the client through the verification process via video call, assisting with document positioning and liveness prompts.

5. Document the limitation: If a client cannot complete verification through any available method, record the reason and your decision about whether to proceed with or decline the business relationship. Regulatory guidance expects documentation of both successful verifications and situations where verification could not be completed.

Regulatory Considerations

• You cannot waive identity verification requirements because a client finds the process inconvenient or difficult. The obligation to verify exists regardless of the method used.
• If you ultimately cannot verify a client’s identity using any acceptable method, you should not proceed with the business relationship.
• Documenting your efforts — the methods attempted, the failures encountered, and the alternative approaches offered — demonstrates good faith compliance even when verification is not completed.

How Athenty Can Help

Athenty, a verification intelligence company, provides Smart IDV and KYC services designed to maximize accessibility and minimize verification barriers.

1. Broad document support: Smart IDV accepts a wide range of government-issued photo IDs from multiple jurisdictions, maximizing the number of clients who can complete electronic verification.

2. Mobile-optimized experience: The verification workflow is designed for smartphones and tablets, with clear prompts that guide clients through each step.

3. Detailed attempt records: Every verification attempt — successful or not — is recorded with timestamps and failure reasons, providing the documentation you need if a client ultimately cannot complete the process.

4. Fallback support: When electronic verification is not feasible, Athenty’s verification reports can be supplemented with documentation from alternative verification methods, maintaining a complete compliance record.

Conclusion

A client who cannot complete electronic identity verification is not a compliance dead end — it is a situation that requires alternative approaches and careful documentation. By offering in-person verification, dual-process methods, or assisted verification where available, and by documenting every effort, your business can maintain both its compliance obligations and its client relationships.