Remote onboarding with a four-part name and third-party address evidence
Meridian Pay, a Singapore-licensed e-money institution, is onboarding Ms. Maria Cristina dela Cruz Santos, a 34-year-old freelance graphic designer in Manila, for a multi-currency account to receive USD payments from overseas platforms. She submits a Philippine passport (name: Maria Cristina dela Cruz Santos), a liveness-checked selfie, and a mobile-phone bill in her mother's name as proof of address. The bill shows "Maria C. Santos." The address-verification vendor returns a partial match and flags the document as 11 months old. She has no bank statement because she is unbanked and cannot produce a tenancy agreement; she says she lives with family. Expected monthly inflows are USD 3,000–5,000, with counterparties in the US and Australia. Sanctions and adverse-media screening return no match. The onboarding queue has a 48-hour SLA, and the case owner is under pressure to clear the backlog. Her name has four components, and the platform's matching logic flags the maternal surname as a mismatch.
1. Assess which CDD elements are satisfied, which are not, and why the name discrepancy is not automatically a failure.
Read the worked answer
Satisfied: identification of the individual via a valid passport and liveness check, subject to checking the passport's machine-readable zone, and a clear enough purpose and expected activity (freelance platform receipts) to set a profile. Not satisfied: address. A mobile-phone bill in the mother's name is not evidence that Ms. Santos lives there, and the name on it is a partial match, not her full name. Source of funds is plausible but unverified; "freelance platforms" needs evidence of platform accounts and payout history. The four-part name is not itself a red flag. Filipino naming conventions commonly include maternal surnames, and matching systems often mishandle them. But the bank cannot waive verification simply because the explanation is culturally plausible; it needs independent corroboration. The file is therefore incomplete, not automatically suspicious.
2. What additional steps would you take before approval, and what would cause you to decline or escalate?
Read the worked answer
Request a secondary government-issued ID showing the full name (driver's licence, national ID, or NBI clearance), plus a document tying her to the address: a utility bill in her own name, a barangay certificate, or a landlord letter with the landlord's ID and a lease receipt. Verify the name variants against sanctions and adverse media. Obtain screenshots or statements from the freelance platforms showing her profile, payout history, and that the account is in her name. If she cannot provide any independent address evidence, decline or keep the account in a restricted, non-funded status. Escalate if the platform accounts are in another person's name, if she refuses to explain the mother's bill, or if screening of the full name or variants returns a possible match. Do not approve on the basis of the vendor's partial match alone.
3. If the account is approved, what conditions and monitoring would you set for the first 90 days?
Read the worked answer
Set initial inflow limits, for example USD 3,000 per month for the first 90 days; hold first receipts until platform statements are verified; prohibit third-party funding; and require reviews at 30 and 90 days. Monitor for round amounts, multiple senders, and rapid pass-through. Re-verify the address at the first review. The rationale is proportionality: the risk is moderate, not high, but the verification gap must be closed before limits are lifted. Document the rationale for the vendor exception and the name-matching decision so a reviewer can see why the bank proceeded and what changed.