IEIM902440 | Verification where the Seller does not Co-operate

Most aspects of the verification process rely on information held by the Reporting Platform Operator (RPO), whether collected as part of its onboarding process, for its own commercial reasons or to comply with other regulatory obligations. However, there may be situations where RPOs require cooperation from Sellers to satisfactorily verify information, including, for example, cases where there are doubts about the reliability of the information collected from the Seller.

Where a Seller, explicitly or otherwise, declines to co-operate with the RPO, the RPO would need to consider what further action if any to take. This could include actions such as temporarily suspending the Seller’s access to the Platform until the Seller starts to co-operate, e.g. by providing further documentation or addressing the RPO’s questions or concerns (see 902430). It is up to the RPO to decide in the circumstances what action(s) it will take, but it is ultimately the responsibility of the RPO to ensure it meets its due diligence obligations.