The CDD engine · shared across the AML family

One customer check. A verdict you can show a regulator.

Every EveryGuard AML product — AgentGuard, FirmGuard, PracticeGuard, ArtGuard — runs customer due diligence on the same engine: a link the customer opens on their own phone, an identity check that reads the document (or, on iPhone, the passport chip itself), a live sanctions & PEP screen, and a locked evidence pack the firm can hand a regulator. This page shows how it all fits together.

5 screensno app install required
OFSI · FCDO
OFAC · UN
sanctions lists, refreshed daily
5 yearsevidence retention, MLR Reg 40
4 verticalsone engine, four regulated professions
How it fits together

One link. A few minutes on their phone. A verdict.

Every check follows the same six-step path, whichever Guard product sent it. Steps run mostly on the customer's device — the firm never has to be in the room.

1

Send the link

The firm sends a one-time verify link by SMS or email — verify.agentguard.uk/{token} (or verify.everyguard.uk for the other verticals). Nothing to install to receive it.

2

Photograph the ID

The customer picks passport, UK driving licence or BRP and photographs it. On-device OCR reads it instantly; a Claude Vision fallback rescues a bad scan.

3

Or tap the chip

On iPhone, the customer can instead tap their ePassport's NFC chip via the AgentGuard Verify App Clip — a cryptographically state-signed read, no photo needed.

Premium · iPhone
4

Selfie & face match

A short liveness check (smile / hand gesture) confirms a live person, then the selfie is matched server-side against the document photo.

5

Screened in parallel

The name is checked against sanctions (OFSI/FCDO/OFAC/UN) and PEP lists, refreshed daily, with a freshness gate that escalates rather than clearing against a stale list.

6

Verdict + evidence pack

The firm gets a clear verdict — clear, review or match — and a locked, audit-ready evidence pack retained for 5 years under MLR Reg 40.

What the customer sees

Built for a phone, start to finish.

No portal login, no PDF to print and scan back. Four moments from the same five-screen flow.

Step 2 of 5
Scan your passport
Reading document…
CaptureOn-device OCR reads the passport MRZ in seconds — no upload needed for the happy path.
App Clip
Hold near the passport
Premium · iPhone
Reading chip data…
Chip readA cryptographically state-signed read of the passport chip — the strongest available proof of the document.
Step 4 of 5
Quick liveness check
Please smile
Selfie & livenessA quick challenge, then the selfie is matched server-side against the document photo.
Identity verified
Screened against sanctions & PEP lists
Verdict: Clear
SubmittedThe customer sees a plain confirmation. The firm gets the full verdict and evidence pack.
Sanctions & PEP screening

Checked against the lists that matter — every time.

The legally-binding lists, plus PEPs

Every check screens the name against OFSI, FCDO, OFAC and UN sanctions data, Companies House disqualified directors, and a Politically Exposed Persons roster — refreshed daily.

Never a silent clear on stale data

If a binding source (OFSI/OFAC/UN) is behind on its refresh, a would-be "clear" verdict is escalated to "review" instead — staleness can only add caution, it can never remove it, and a genuine match is never downgraded.

Matching tuned against false positives

Name matching combines fuzzy scoring with a surname-support check, so a customer who happens to share a first name with a sanctioned individual isn't wrongly flagged — while genuine matches, reordered names and typos still surface for review.

Verdict combination
Sanctions match
→ Match
List stale, would clear
→ Review
Face no-match, sanctions clear
→ Review
Clear + face match
→ Clear
A below-threshold or ambiguous result never resolves itself to "clear" automatically — it routes to a human for review. Every screening writes a byte-for-byte replay of the match, so a verdict from months ago can be re-examined exactly as it was reached.
Two assurance tiers
Works onEvery device
Face matchLive · standard
Match methodCosine distance, face descriptors
Below thresholdRoutes to review, never blocks
NFC chip readPremium · iPhone
AssuranceCryptographic, state-signed
Image bytesNever leave the device
AndroidIn build
Identity assurance

Two ways to bind the person to the document.

Server-side face match, on every device

The live selfie taken during liveness is matched, server-side, against the portrait on the ID document — closing the gap a liveness challenge alone can't: proving the person holding the phone is the person on the document, not just that a live face was in frame.

Passport-chip read, on iPhone

Tapping the ePassport's NFC chip via the AgentGuard Verify App Clip reads a cryptographically signed identity record straight from the document — the strongest tier available, and the one competitors charge most for. Live on the App Store as a premium option; the equivalent Android build is still in progress.

What the firm gets back

A verdict, and the evidence to back it up.

An audit-ready evidence pack

Document image, selfie, face-match distance, the sanctions/PEP screening replay with the list version and fetch date used, and the full activity timeline — downloadable as PDF, or a ZIP of the whole pack. Not a badge for the customer to see; a private file the firm can hand a regulator.

Locked, 5-year retention

Evidence is retained for 5 years per MLR Reg 40 with an application-level retention lock, and — where a dedicated evidence bucket is provisioned — S3 object-lock that even an administrator can't override early. Every view of a customer's ID imagery is itself logged.

Optional ongoing monitoring

A firm can opt a customer into monthly, quarterly or annual re-screening against fresh sanctions and PEP data — no re-contact needed — with a monitoring-run record written either way, because "no change" is itself evidence.

Inside the evidence pack
IdentityDocument + selfie + match verdict
ScreeningList version & fetch date, per source
Activity logLink sent → opened → completed
Chip read (if used)Signature status, CSCA country
Customer historyPrior checks — dates & verdicts only
Retention5 years · MLR Reg 40
ExportPDF · full-pack ZIP
One engine, several front doors

The same CDD engine, wherever AML applies.

Build the identity-verification and screening engine once, point it at the next regulated profession. Each product adds its own onboarding, pricing and regulator-specific detail on top of the same verify flow, matcher and evidence pack.

AgentGuard

Estate & letting agents

The engine's original home — full CDD suite plus continuous AML compliance scanning against HMRC supervision and redress rules.

FirmGuard

Solicitors & law firms

Client due diligence for SRA-regulated firms, alongside the SRA Transparency Rules scan and the Legal Sector Affinity Group policy pack.

PracticeGuard

Accountants & bookkeepers

Client due diligence with sanctions & PEP screening for HMRC-supervised accountancy practices.

ArtGuard

Art & antiques dealers

Client & provenance due diligence for HMRC-supervised art-market participants under the Money Laundering Regulations.

The same verify flow also underpins right-to-work identity capture for care and visa-sponsor customers — same document read, same face match, a different purpose flag rather than a different codebase.

What this is — and isn't

Said plainly, because that's the standard we hold ourselves to.

We'd rather tell you where the edges are than let a customer or a regulator find them first.

Liveness aloneis a weak signal

A random head or hand challenge on its own only proves a live person was in front of the camera — it doesn't prove that person is the document holder. That binding comes from the server-side face match (standard) or the passport-chip read (premium), not from liveness by itself.

The chip readis a premium, iPhone-only tierPremium

The AgentGuard Verify App Clip is live on the App Store and reads the NFC chip in an ePassport. It's an iPhone-only, opt-in upgrade tier, not the default path — most checks complete on photo + face match. The Android equivalent is still being built.

Ambiguity escalatesit never resolves itself

A below-threshold face match, an unreadable document, or a stale sanctions list never silently clears a customer — each routes to a human review. A genuine sanctions or PEP match is never downgraded by anything downstream.

No automated EDDworkflow, yet

Enhanced due diligence on a PEP or review case is a human decision an operator records — there's no automated EDD workflow behind it yet. Ongoing monitoring is opt-in per customer, not switched on for everyone by default.

See it running today.

The engine described here is live in production on AgentGuard, FirmGuard, PracticeGuard and ArtGuard — not a roadmap.

Visit AgentGuard →