On December 10, 2021, the European Banking Authority (EBA) launched a Consultation Paper on its Draft Guidelines on the use of Remote Customer Onboarding Solutions (the Consultation Paper) that will run until March 10.

These Draft Guidelines set common standards for a robust and safe customer due diligence (CDD) program in line with the anti-money laundering and counter financing of terrorism (AML/CFT) as well as data protection requirements.

With current trends towards digital tools to onboard customers remotely, these guidelines sets expectations in these key areas:

• Internal policies and procedures

• Acquisition of information identifying the customer / natural persons / legal entities and including the nature and purpose of the business relationship

• Document authenticity and integrity, including various collection methods such as optical character recognition (OCR) algorithms or customer devices

• Authenticity checks, including expectations for using different verification methods such as biometric or video conferencing and for situations with increased levels of money laundering or terrorist financing risks

• Use of digital identities with the goal to reduce risk of impersonation, misuse or alteration of identity

• Reliance on third parties and outsourcing

• Information and communications technology (ICT) and security and risk management

The finalized Guidelines will apply to all financial institutions subject to the Anti-money Laundering Directive (AMLD).