MLR 2017 reg. 28 sets the core of customer due diligence: identify the customer, then verify identity from documents or information obtained from a reliable source that is independent of that customer. Reg. 33 adds enhanced measures where the risk is higher. Reg. 40 then requires the evidence to be kept for five years after the business relationship ends. JMLSG guidance, approved by HM Treasury, describes what that looks like in a UK bank. Keeping the pack is a legal duty; sharing it is not. anonym.plus marks each identifier on your machine, so the proof of review survives while the raw identity evidence is shielded.
When this applies
An external examiner reviews how the team applies its risk model. The passport image, the National Insurance number and the address proof are evidence you must keep, not evidence the examiner needs to read. You hand over a masked pack and leave the original in the secured system.
How anonym.plus handles it
- Open the pack in anonym.plus on your device.
- Local OCR reads the scanned ID and address proof.
- It flags the name, NINO, and document numbers.
- Confirm the flags and keep the review checklist.
- Swap or black out the confirmed items.
- Save the clean file locally.
What you need to provide
- The KYC pack (PDF, image scan, DOCX).
- An operator (Redact suits ID scans).
- Optional batch for a queue of customer files.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Priya Nair → [CUSTOMER] |
| Identifiers | UK_NINO | QQ 33 07 12 A → [NINO] |
| Identifiers | UK_PASSPORT | passport 123456789 → [PASSPORT] |
| Contact | PHONE_NUMBER | +44 161 555 0142 → [PHONE] |
| Location | LOCATION | proof of address → [ADDRESS] |
| Dates | DATE_TIME | DOB 1969 → [DOB] |
Compliance achieved
- Shields the identity evidence gathered under MLR 2017 reg. 28, and the extra material reg. 33 calls for in higher-risk cases.
- Leaves the retained original intact for the five-year period in MLR 2017 reg. 40.
- Fits the record practice set out in JMLSG guidance, approved by HM Treasury.
- Local OCR reads ID scans, so printed document numbers are caught, not just typed ones.
- Offline work keeps identity records off any server; 340+ PII types are covered.
Anonymise KYC files offline — see plans & start free →
Limitations & cautions
A redacted pack no longer proves identity, so the unredacted original must stay in your secured system for the whole reg. 40 period. The tool flags named items; it cannot judge every visual clue on a photo page.
Frequently asked questions
Why redact a pack I am required to retain?
Because retention and disclosure are different duties. MLR 2017 reg. 40 makes you keep the original for five years after the relationship ends. Nothing in it says a trainer, vendor or analyst needs to read the passport number, so the copy they see is the masked one.
Can the tool read a passport image?
Yes. Local OCR (Tesseract) reads the scan first, then flags the name and document numbers for review. Check the machine-readable zone as well as the printed page — it repeats the same values in a different format.
Does anything go to the cloud?
No. The app is fully offline, so identity evidence stays on your device and never creates a second copy outside the firm.