IEIM902420 - Determining Reliability

Reporting Platform Operators (RPOs) must determine whether information is reliable using all the information available to them. For example, if a Seller provides a name when signing up to the Platform, but the email address they provide, and/or the bank account information they provide gives another name, that would create doubt as to whether the name provided was reliable.

Some RPOs will collect additional documentation from Sellers. For example, where a Seller has to drive as part of their job, the RPO may require them to provide their driving licence. AML-obliged RPOs may require a copy of a passport or other photo ID. Where this documentation is collected by the RPO, it should be matched against other information collected, such as name and date of birth. Again any discrepancies would be a cause for doubt as to the reliability of the information.

Some relevant services may require a licence or other authorisation from a local authority. When the RPO verifies that such licenses or authorisations are in place, it would need to verify that this information matched the information it held. Where this was not the case, this would cast doubt upon the reliability of the information provided.

Many RPOs will have information about where relevant services are performed, for example if services are performed in person at a customer’s premises. Equally a Platform would have information on the jobs and routes taken by drivers or riders, as well as geographical information from GPS systems. IP addresses used to log on to the Platform, or the telephone number used to access an app for the Platform, may provide further information about the location of the Seller. Where a primary address is given in one jurisdiction, but the Platform information indicates a strong relationship with another jurisdiction, based on the services provided and where the Platform is accessed from, that could indicate that the Primary Address information provided by the Seller is not reliable.

Where the Seller is selling goods via the Platform, the RPO is likely to have addresses for shipping returns and billing. These may not be determinative of the Seller’s address, for example, all shipping might be to and from a warehouse in one jurisdiction, but the Seller might live in another. However, the different addresses provided might be one factor amongst others that indicates potential doubt over the jurisdiction where the person is resident. The primary address could also be matched to the jurisdiction that issued the Seller’s TIN as a further test as to the reliability of the information collected.

RPOs are not under a general obligation to require additional documentation from Sellers beyond what they already collect in line with their onboarding, commercial or regulatory requirements. However, and particularly in cases of doubt, RPOs may seek additional documentation to assure themselves that the information collected is reliable.