The first question is how will non-documentary ID verification be completed? If you're using a vendor, how comfortable are you with their data sources? Besides CIP information, what CDD information will be requested? How will you handle accounts where the CIP or CDD information cannot be verified automatically? There are other questions to be answered but these are the ones I would focus on first.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu