RE: AML Question - Security Recommendation

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Driver's license is considered Sensitive Personal Information and therefore
it is highly recommended that:

a) It is not stored or copied but there should be documented process to
demonstrate that the driver's license has been validated;

b) If there is a demostrabe business need to store this information
there has to be a secure means of recording it, transferring it over the
wire (aka encryption) and protected while at rest at the destination
(encryption and access restrictions especially if on a hosted cloud).

Hope that helps.



Pamela Gupta CISSP CISM CSSLP

President & Founder | OutSecure Inc. | Shelton Pointe, Suite 401 2 Trap
Falls Road Shelton CT 06484 | 1(203)816-8061 | www.outsecure.com
Follow OutSecure on Twitter
| www.linkedin/in/pamelagupta
| Follow Pamela on Twitter






From: Audrey Wheeler [mailto:aharris@mcdonald-partners.com]
Sent: Thursday, September 1, 2016 4:45 PM
To: IA Week Listserv
Subject: RE: AML Question



Make a copy



Audrey Wheeler







Audrey Wheeler

Chief Compliance Officer

216-912-0558 Direct

216-912-1461 Fax

aharris@mcdonald-partners.com

Please note: We have moved! Our new address is below



McDonald Partners LLC

1301 East 9th Street, Suite 3700

Cleveland, OH 44114

Visit our new website www.McDonald-Partners.com








Attention: This transmission is neither an offer nor a solicitation of an
offer to buy or sell securities. Please be aware that the confidentiality of
Internet email cannot be guaranteed. Please do not include private or
confidential information such as passwords, account numbers, social security
numbers, etc, in emails to us. If you are not the intended recipient, you
are strictly prohibited from disclosing, copying, distributing or using any
of this information, please contact the sender immediately and destroy the
material in its entirety. Additionally, instructions having financial
consequences such as trade orders, funds transfer, etc., should not be
included in your email communications to us as we cannot act on such
instructions by email. Accompanying information was prepared by or obtained
from sources which McDonald Partners LLC., believes to be reliable but does
not guarantee its accuracy.

_____





From: Carl Ayers [mailto:cayers@ucg.com]
Sent: Thursday, September 01, 2016 4:24 PM
To: IA Week Listserv
Subject: AML Question



A peer asks that we ask you this simple AML question. Please hit reply and
send in your answer. Thanks, Carl



Do you make a copy of new client's driver's license (or other government
issued Identification document) to keep in the client file or do you simply
take down the number?



Carl Ayers

Publisher, IA Watch

Two Washingtonian Center

9737 Washingtonian Blvd., Suite 502

Gaithersburg, MD 20878

Link to me via LinkedIN

301-287-2435

Fax: 301-287-2121

http://www.iawatch.com/carlayers

cayers@iawatch.com

iawatch.com

Our YouTube Channel: www.iawatch.com/youtube






For the first time, Boston hosts an IA Watch compliance conference. Make
your plans today to join us at our Commitment to Compliance on Monday, Sept.
26, 2016.

We?ll be at the Hyatt Regency Downtown Boston.

Check out the entire agenda and register at http://www.iawatch.com/Fall2016/
or call us toll-free at 888-234-7281.

Connect with IA Watch via Facebook and Twitter.

For the first time, Boston hosts an IA Watch compliance conference. Make
your plans today to join us at our Commitment to Compliance on Monday, Sept.
26, 2016.

We'll be at the Hyatt Regency Downtown Boston.

Check out the entire agenda and register at http://www.iawatch.com/Fall2016/
or call us toll-free at 888-234-7281.

Connect with IA Watch via Facebook and Twitter.


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Driver’s license is considered Sensitive =
Personal Information and therefore it is highly recommended =
that:

a)      =
It is not =
stored or copied but there should be documented process to demonstrate =
that the driver’s license has been =
validated;

b)      =
If there is =
a demostrabe business need to store this information there has to be a =
secure means of recording it, transferring it over the wire (aka =
encryption) and protected while at rest at the destination (encryption =
and access restrictions especially if on a hosted =
cloud).

Hope that helps.

 

Pamela Gupta CISSP CISM =
CSSLP

President & Founder =
| OutSecure Inc. | Shelton Pointe, Suite 401  2 Trap Falls Road =
Shelton CT 06484 | 1(203)816-8061 | www.outsecure.com Follow OutSecure on =
Twitter
 | www.linkedin/in/pamelagupta | Follow Pamela on =
Twitter

 

 

From: Audrey Wheeler =
[mailto:aharris@mcdonald-partners.com]
Sent: Thursday, =
September 1, 2016 4:45 PM
To: IA Week Listserv =
<iaweek-l@list.ucg.com>
Subject: RE: AML =
Question

 

Make a =
copy

 

Audrey =
Wheeler

 

 

 

Audrey =
Wheeler

Chief Compliance =
Officer

216-912-0558 =
Direct

216-912-1461 =
Fax

aharris@mcdonald-partners.c=
om

Please =
note:   We have moved!    Our new address is =
below

 

McDonald =
Partners LLC

1301 East 9th =
Street, Suite 3700

Cleveland, =
OH  44114

Visit our new =
website  www.McDonald-Partners.com

 

 

3D

Attention: This transmission =
is neither an offer nor a solicitation of an offer to buy or sell =
securities. Please be aware that the confidentiality of Internet email =
cannot be guaranteed.  Please do not include private or =
confidential information such as passwords, account numbers, social =
security numbers, etc, in emails to us.  If you are not the =
intended recipient, you are strictly prohibited from disclosing, =
copying, distributing or using any of this information, please contact =
the sender immediately and destroy the material in its entirety.  =
Additionally, instructions having financial consequences such as trade =
orders, funds transfer, etc., should not be included in your email =
communications to us as we cannot act on such instructions by email. =
Accompanying information was prepared by or obtained from sources which =
McDonald Partners LLC., believes to be reliable but does not guarantee =
its accuracy.

 

 

From: Carl Ayers [mailto:cayers@ucg.com] =

Sent: Thursday, September 01, 2016 4:24 PM
To: IA =
Week Listserv <iaweek-l@list.ucg.com>
Subject: AML Question

 

A peer asks =
that we ask you this simple AML question. Please hit reply and send in =
your answer. Thanks, Carl

 

Do you make =
a copy of new client’s driver’s license (or other government =
issued Identification document) to keep in the client file or do you =
simply take down the number?

 

Carl Ayers

Publisher, IA Watch

Two Washingtonian Center

9737 Washingtonian Blvd., Suite 502

Gaithersburg, MD 20878

Link =
to me via LinkedIN

301-287-2435

Fax: =
301-287-2121

http://www.iawatch.com/carlayer=
s

cayers@iawatch.com

iawatch.com

Our YouTube Channel: www.iawatch.com/youtube

 

 

For the first time, Boston =
hosts an IA Watch compliance conference. Make your plans today to =
join us at our Commitment to Compliance on Monday, Sept. 26, =
2016.

We?ll be at the Hyatt Regency Downtown =
Boston.

Check out the entire agenda and register at http://www.iawatch.com/Fall2016=
/
or call us toll-free at 888-234-7281.

Connect =
with IA Watch via Facebook and Twitter.

For the first =
time, Boston hosts an IA Watch compliance conference. Make your =
plans today to join us at our Commitment to Compliance on Monday, =
Sept. 26, 2016.

We’ll be at the Hyatt Regency =
Downtown Boston.

Check out the entire agenda and =
register at http://www.iawatch.com/Fall2016=
/
or call us toll-free at 888-234-7281.

Connect =
with IA Watch via Facebook and =
Twitter.

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