In their 'Dear CEO' letter from 31st March, the FCA makes clear that the obligations on firms to meet client identification requirements remain, despite the limitations on non-essential travel making traditional verification more of challenge. But they do recognise that there can be flexibility in how this can be done. 

Perhaps we can go one step further and, with necessity being the mother of invention, use this crisis to encourage the adoption of new approaches to identify client risk and help us to focus on what matters. The move towards more insightful technology could be accelerated by the challenges we now face.