However, our experience shows that this method is impractical. One way to potentially mitigate the risk of manipulation is to contact the person that has certified the document in question to confirm the details in the document and the fact that they have indeed certified it. A certification, in this case, loses its utility value. It is just as prone to manipulation as a scanned copy of any other document. In contrast, a scanned version of a ‘certified copy’ is no longer the very copy that has been sighted and confirmed as a true copy of the original by an authorised person. Therefore, a reporting entity can be reasonably certain that the ‘certified copy’ is the same as the original document without signs of manipulation, and can rely on the information in the certified copy for KYC purposes. The rationale behind obtaining a certified copy of a document is that a person authorised by the Rules has sighted the original document and the copy, and has confirmed that the copy is the same as the original. The provision then goes on to provide a list of persons authorised to certify documents under the Rules. 1) (Cth) (the ‘ AML/CTF Rules’, the ‘ Rules’) to refer to ‘a document that has been certified as a true copy of an original document…’. The term ‘certified copy’ is defined in Part 1.2 of the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. I share my thoughts on the topic and what reporting entities need to consider in deciding their own approach in this article below. However, I would be inclined to think that a scanned copy of a certified document is no longer a ‘certified copy’. This is understandable as it is much faster and easier to obtain a scanned copy than waiting for the physical certified document to arrive. There appears to be an increase in the acceptance of scanned copies of certified documents in recent years.
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