If you are in scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended, you must comply with the statutory requirements at all times, irrespective of your working arrangements. The coronavirus (COVID-19) pandemic necessitated a shift to remote working, and it has remained widely adopted since, however, identifying your client and verifying their identity is still just as important and a key part of the client due diligence (CDD) process. Criminals continued to operate during the pandemic, and some sought to take advantage of the situation. Remote and hybrid working arrangements that have continued beyond the pandemic mean many of the CDD challenges first considered during that time remain relevant, as criminals continue to try to take advantage. You should consider the risks associated with acting for clients without meeting them in your firm-wide risk assessment (FWRA). This in turn will need to cascade through to policies, controls and procedures you put in place to manage the risks you