On 10 December 2021, the European Banking Authority (EBA) launched a public consultation on draft guidelines on the use of remote customer onboarding solutions.

The draft guidelines have been developed in response to the European Commission’s request in the context of its Digital Finance Strategy, published in 2020. They are also in line with the EBA’s legal mandate to lead, coordinate and monitor the EU financial sector’s fight against money laundering / terrorist financing.

The draft guidelines set common EU standards on the development and implementation of sound, risk-sensitive initial customer due diligence (CDD) processes in the remote customer onboarding context. They set out the steps EU financial sector operators should follow when choosing remote customer onboarding tools and what financial sector operators should do to satisfy themselves that the chosen tool is adequate and reliable on an ongoing basis and allows them to comply effectively with their initial  CDD obligations. While the draft guidelines address initial CDD obligations, they do not prevent EU financial sector operators from gathering all information needed to perform all CDD obligations at the same time as they are performing initial CDD remotely. The draft guidelines are clear that the choice of individual technological solutions is the financial sector operators’, to the extent that this is permitted by national law.

The deadline for comments on the draft guidelines is 10 March 2022.

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