Circumventing identity-related risks in the banking sector

Imagine an individual walking into a bank with a stolen cheque, seeking to open an account using the names on the cheque. Or this ‘customer’ presents a passport to withdraw money, only for the teller to establish that the details do not match what the account in question suggests. Those in the banking sector are better placed to give many more similar stories relating to forgeries and fraud. Some of the most common types of economic crimes committed by perpetrators include credit card fraud, identity theft and forgery. Kenya's Banking Fraud Investigation Unit (BFIU) exists to receive and investigate fraud complaints from commercial banks and other institutions, advise banks on fraud prevention and detection strategies; and sensitise the public on common types of fraud as well as to liaise with other agencies to fight fraud and recover stolen money and restitute the amounts to the rightful owners. Banks are expected to liaise with the BFIU even as they have the capacity to detect and mitigate many of these risks themselves. The banking sector remains a pillar in the development of the country. Individuals and companies alike rely on the banking sector to conduct crucial financial transactions. Given this critical role, banks have every reason to take risk management very seriously. Identity documents are used as feeder documents to onboard a client and to identify a customer before transacting. When one presents a national identity card and/or a passport to identify themselves, a bank official makes a comparison between the details in the bank’s database and the person and documents before them and uses that comparison to make decisions. The use of identity documents (and lately, biometric recognition) presents risks that need to be considered and prepared for. For instance, a document forgery could portend millions of shillings in losses to the institution. A case of identity theft could cost the bank significant money and lead to serious reputational damage. Document fraudsters have access to many identity-related schemes such as bio-data alterations, identity fraud, fraudulently obtained genuine documents, use of fantasy and camouflage documents or the use of complete counterfeit documents. It is important therefore that banks and other financial institutions put in place strategies that mitigate against these risks. Two related strategies can help circumvent identity theft related risks. First, the banking sector should invest in efforts to build the capacity of its staff. Capacity building could involve workshops and training aimed at better equipping the bank’s staff to identify instances of potential fraud. Certain training can empower staff to conduct an effective document check and since fraudsters are always a step ahead, refresher courses need to be part of the bank’s training schedule.

"To build on the image and reputation of the banking institutions, it is the bank’s responsibility to detect forged documents and avoid the risks associated with this type of fraud. "

Additional questions that banks should address include:

  • What red flags should prompt a bank to seek verification of documents?
  • What common forgery typologies are they likely to encounter?
  • How do they detect imposters?
  • How do they identify genuine, stolen blank documents?
  • Does the customer’s traveler history fit in the customer’s profile or what the customer is telling the bank?
  • How does a customer’s profile correspond to the non-verbal cues and customer’s body language?

The second strategy involves verification. With a clear red flag having been identified, who makes the call? Governmental agencies or a foreign country's Embassy (or Mission Office) in Kenya can help to verify certain documents. Developing trusted relationships with the verification teams within these institutions could help the bank to manage certain identity-related risks. To build on the image and reputation of the banking institutions, it is the bank’s responsibility to detect forged documents and avoid the risks associated with this type of fraud. Training and equipping the various teams of senior managers, tellers, verification and risk teams could help curb mischief from fraudsters. Additionally, banks can liaise with different verification units to check identity documents. As always, it is advisable to seek experienced advice from a trusted partner who can provide the necessary support and guidance as banks tackle identity theft and related risks.

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Robert Aswani

Senior Manager - Tax at PwC Kenya

T: +254 20 285 5729 E: robert.aswani@pwc.com

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Josphat Muchiri

Manager - Tax at PwC Kenya

T: +254 20 285 5242 E: josphat.muchiri@pwc.com