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🔍 ARNECC VOI FAQ – Face-to-Face and Online Identity Verification | Realaml Help Center

🔍 ARNECC VOI FAQ – Face-to-Face and Online Identity Verification

ARNECC VOI FAQ: Learn the difference between in-person and online identity verification under ARNECC’s VOI Standard and Reasonable Steps.

Written by Jordan
Updated over a year agoJordan

âť“ What are the ARNECC requirements for verifying identity?

ARNECC outlines two accepted methods for Verification of Identity (VOI) under the Model Participation Rules (MPRs):

  1. The VOI Standard – a prescriptive, in-person method

  2. The Reasonable Steps approach – a flexible method used when the VOI Standard isn’t practical

The VOI Standard – a prescriptive, in-person method

The Reasonable Steps approach – a flexible method used when the VOI Standard isn’t practical

âť“ What is the VOI Standard?

The VOI Standard is the preferred method and requires:

  • A face-to-face interview, either by you or a trusted Identity Agent (e.g., Australia Post)

  • The person presenting original, physical identity documents

  • Use of specific document combinations from VOI Categories 1–7

  • Retention of a VOI record showing:

    • The verifier's details

    • The date and location

    • The documents sighted

    • Confirmation that the VOI Standard was followed

A face-to-face interview, either by you or a trusted Identity Agent (e.g., Australia Post)

The person presenting original, physical identity documents

Use of specific document combinations from VOI Categories 1–7

Retention of a VOI record showing:

  • The verifier's details

  • The verifier's details

  • The date and location

  • The date and location

  • The documents sighted

  • The documents sighted

  • Confirmation that the VOI Standard was followed

  • Confirmation that the VOI Standard was followed

    🔹 Biometrics and electronic verification are not required under the VOI Standard.

    ❓ Can I verify someone’s identity online?

    Yes — but ARNECC doesn’t specifically mention “online verification.” Instead, it allows for a Reasonable Steps approach when in-person verification is not possible or practical. This flexibility has become more relevant since COVID.

    âť“ What is the Reasonable Steps approach?

    The Reasonable Steps method allows you to verify identity in alternative ways (including digitally) — as long as the steps taken are reasonable in the circumstances and provide a high level of confidence that the person is who they claim to be.

    âť“ What should an ARNECC-compliant online VOI process include?

    To be considered compliant under the Reasonable Steps framework, an online identity verification process should include:

    • âś… Verification of name, date of birth, and address from two or more independent and reliable data sources

    • âś… Biometric face matching with liveness detection (e.g., a selfie or video matched to the ID photo)

    • âś… Consent from the individual being verified

    • âś… Secure storage of:

      • Match results

      • Timestamps and IP/geolocation

      • Verification method

      • Risk decisions

    • âś… Clear justification for not using the in-person VOI Standard (e.g., remote client, international location)

    • âś… Optional risk checks like PEP & sanctions screening, and fraud flag detection (e.g., VPN usage)

    âś… Verification of name, date of birth, and address from two or more independent and reliable data sources

    âś… Biometric face matching with liveness detection (e.g., a selfie or video matched to the ID photo)

    âś… Consent from the individual being verified

    âś… Secure storage of:

    • Match results

    • Match results

    • Timestamps and IP/geolocation

    • Timestamps and IP/geolocation

    • Verification method

    • Verification method

    • Risk decisions

    • Risk decisions

      âś… Clear justification for not using the in-person VOI Standard (e.g., remote client, international location)

      âś… Optional risk checks like PEP & sanctions screening, and fraud flag detection (e.g., VPN usage)

      âť“ Is Realaml's online VOI compliant with ARNECC?

      Yes — Realaml’s identity verification process can meet ARNECC’s Reasonable Steps requirements, provided:

      • Two independent data sources are used to verify name, DOB, and address

      • Biometric facial matching and liveness detection are included

      • Full audit trails are maintained

      • Consent is obtained

      • The online method is used in situations where in-person verification is not practical

      Two independent data sources are used to verify name, DOB, and address

      Biometric facial matching and liveness detection are included

      Full audit trails are maintained

      Consent is obtained

      The online method is used in situations where in-person verification is not practical

      âť“ How does ARNECC VOI compare to AUSTRAC KYC/CDD?

      ARNECC VOI is narrowly focused on identity verification for land transactions.
      In contrast, AUSTRAC’s KYC/CDD (Know Your Customer / Customer Due Diligence) obligations are more robust and comprehensive, covering:

      • Customer risk profiling

      • Source of funds and wealth

      • Ongoing monitoring and due diligence

      • Suspicious matter reporting

      Customer risk profiling

      Source of funds and wealth

      Ongoing monitoring and due diligence

      Suspicious matter reporting

      👉 VOI can form part of AUSTRAC compliance — but not a substitute for full KYC/CDD processes.