Overview
The identity check uses data from TransUnion to verify whether an individual is who they say they are. It is designed to meet the requirements set by the Money Laundering Regulations and the Joint Money Laundering Steering Group.
A score of 35 is the highest possible result.
A score of 35 or above is an accept.
A score below 35 is a fail.
However, some lower scores still satisfy anti-money laundering requirements, as explained below.
How the ID check score is calculated
The system combines data points to return a score out of 35:
+10 points – Two primary identity and address checks are confirmed (meets Joint Money Laundering Steering Group requirements)
+20 points – The individual is found on the TransUnion database
–5 points – The applicant has been on the electoral roll for less than 12 months
+5 points – A sufficient match (49% or more) of date of birth with TransUnion’s records
ID warnings
The following conditions trigger an automatic fail by deducting 20 points:
The applicant is a Politically Exposed Person (PEP)
The applicant is on the UK sanctions list
The applicant is a Special Designated Person (international equivalent of UK sanctions)
The applicant is reported as deceased
Address recency warning
If there is a recency warning (i.e. the applicant has only recently moved to their address), 5 points are deducted. This results in a refer, not an automatic fail.
Date of birth confirmation
5 points are awarded if 49% of dates of birth match that provided by the member.
If the individual matches against all of the points above, an accept decision is returned with a score of 35.
If the individual has a recency warning against their address a refer is returned because 5 points are deducted.
Interpreting the scores
35 – A full match across all checks: ID and address, TransUnion presence, date of birth, and electoral roll.
30 – Slight discrepancies, such as:
Electoral roll duration under 12 months
Date of birth mismatch
Address recency warning
These still satisfy Money Laundering Regulations. You may wish to request supporting documents such as a driving licence, passport, or proof of age card, particularly where the date of birth does not match.
Below 30 – A reduced level of confidence. If the applicant has a “thin credit file” (i.e. limited financial history), they may not be found on the TransUnion database or may not have enough primary identifiers.
Warnings triggered – If any ID warning is returned (PEP, sanctions list, deceased), the application is likely to be rejected and further verification is required.
If the identity check fails
You may need to collect paper-based identity documents, such as:
Government-issued ID (passport, driving licence)
Recent utility bill or bank statement showing the applicant’s name and address
These can be used to manually confirm identity and meet your organisation’s due diligence requirements.
Next: Bank Owner verification