Resources for verifying the legitimacy of customers and collaborators
Challenge: rigorous yet inclusive managed access to risky materials
Many providers already conduct KYC screening to decide whether to sell or share materials such as synthetic DNA encoding pathogens and toxins. However, it is not easy to design screening processes that are consistent and rigorous enough to capture potential illegitimate actors while enabling legitimate bioscience and biotechnology. This problem becomes especially apparent when trying to serve customers and collaborators outside of the Global North and established academic settings.
At present, KYC screening often relies on subjective judgments about “legitimacy.” For this reason, IBBIS has engaged in consultations with global stakeholders to develop structured templates and flowcharts for requesting information and verifying legitimacy.
Our Work: practical tools for verifying legitimacy for DNA synthesis
The decision about whether to fulfill an order for synthetic DNA hinges on a judgement about whether the customer should be trusted to receive those sequences. Orders for potentially risky sequences require a higher level of confidence in the customer, meaning that sequence screening and customer screening both feed into the decision.
As part of our Common Mechanism project, IBBIS provides a freely available tool to identify sequences of concern, and has worked to develop practical resources for customer screening to complement this.
Forms and Decision Support for DNA Providers
To support KYC practices for providers of synthetic DNA, IBBIS has developed customer screening forms and decision support resources. These documents are based on international discussions of best practices among these providers, guidance from U.S. and U.K. governments, and feedback from stakeholders.
Refinement of these documents is ongoing, and we would be very interested to hear how they could be improved to better accommodate a wider range of international providers and customers. If you have comments or suggestions, please send us an email at screening@ibbis.bio.
Onboarding New Customers
Customer screening can occur across many parts of the order process, but key checkpoints for verification of legitimacy are during initial customer onboarding and if a customer orders a sequence that is flagged as a sequence of concern.
New Customer Form
The information on this form should be requested during customer onboarding. It will establish that customers are members of the life sciences community and that have a legitimate reason to order synthetic nucleic acids.
This form is available as a fillable PDF, word document, or plain text.
Decision Support for Providers
This decision guide outlines a step-by-step process for providers, such as companies, core facilities, and biofoundries, to decisions based on the information provided on the New Customer Form. This includes how to interpret information on the form, strategies to verify customer identity, and potential red flags.
Team
Project Lead
Tessa Alexanian
Contributors
- Sarah Carter, Technical Consultant
- Lucas Boldrini, Technical Consultant