Here at Simwood, we have a policy on not providing Haynes Manuals to enable scrotes to bypass our controls and processes, which are a line of defence against British citizens being defrauded.
However, that has to be balanced with a broader interest in sharing learning with the rest of the industry, to achieve the same outcome – our grandparents not losing their life savings. Of course, the scrotitude can just move to one of our alleged competitors with less scruples and morals (as we know it does from conversations at ITW), but we prefer our consciences to be clear.
Where we detect odd things occurring on numbers we have suballocated, our systems request the suballocatee to provide various information. At a high level, that’s “This number looks suspicious – can you check you did some KYC and share what you can with us, please”.
What leads to the automated enquiry is definitely Haynes Manual territory, but I am pleased to see that the majority of responses provide detailed information about the end user to whom the number was suballocated. Our customers are very much doing what is expected of them, and doing it well.
However, just like any arms race, the scrotes are getting better too.
In the last few months, I have spotted a trend. Numbers allocated to UK companies, with one sole foreign resident director and shareholder, and, often, the company is dormant. But that’s enough to get a bank account with an e-money institution like Revolut, or Tide, and have all the appearances of having a genuine UK establishment and obtaining UK numbering resources unless whoever is doing the KYC has been around the block enough times to be dizzy.
We see the same thing in the USA too. I won’t say which states are red flags, but there are a couple of them which appear to have low barriers to formation and a plethora of shell companies owned by scrotes.
Specifically, these actions are enough to obtain access inside the international gateway, by a foreign-resident.
It doesn’t take a genius to see where this is going – before you know it, you have a fox in the hen house, DNO alerts lighting up the compliance channel in Slack like a Christmas Tree and a plethora of angry UK consumers.
Each of the cases I have reviewed has been an obvious shell company, with no discernible genuine ties to the UK, the sole purpose of which is seemingly to pass UK KYC for UK numbering resources, and to originate spammy calls from abroad.
I’ve talked about the difference between box-ticking compliance, and embracing it for improvement before. This is another useful example. In one sense, our partner has done the right thing, proven the entity exists, and is actually represented by who is shown at Companies House. This is all good stuff.
On the other hand, they are a bartender who served a teenager by not scrutinising the fake ID sufficiently. And just like that scenario, the law (or regulation) will pierce that veil and hold you liable for insufficient scrutiny of what your customers tell you.
Actually, with the FCC proposing $2,500 per spam call fines, you might wish you were just a humble barkeep – and it won’t be long until Ofcom realises that all those pornographers won’t pay up, and seek to bolster the treasury coffers elsewhere.
