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According to the matrix, ID checks is currently a L1 requirement. The Section in 1.04 should be updated to reflect the control as it is listed on the matrix.
Section 1.04 currently requires ID checks to reach L2 compliance.
This should be amended to be L1.
During an audit of an information system earlier this year it came to light that an operator was operating under a pseudonym at their parent company.
Strong ID checks should be a requirement for all actors with organization-granted access to funds.
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