The EBA has published guidelines on the use of remote customer onboarding. Those will certainly shed light on the procedures to abide to, if having recourse to remote clients’ onboarding solutions, as the CSSF has yet only provided guidance in this field with its FAQs on AML and IT requirements re. onboarding through video chat.
Broadly, the guidelines encompass two core pillars: (i) one related to the. various procedures professionals shall abide to and (ii) another pertaining to the collection/ verification/ authenticity of clients’ information as well as outsourcing considerations and the management of ICT risks.
(i) POLICIES
- 5 steps procedure check (description, situations, automation, controls, training programs)
- Managing the pre-implementation process
- Demonstrating to the competent authority the assessments carried-out
- Monitoring the e-onboarding solution (steps + remediation)
(ii) DOCUMENTATION
- Information to be collected for identification and verification purposes (leeway given here to professionals)
- Document authenticity and Matching of documentation
- Outsourcing and ICT considerations
Kindly note that the Guidelines will enter into force 6 months after their publication in all EU official languages (yet still a work in progress) – meaning that they are yet not applicable.
Monitor therefore the EBA’s webpage to know about the completion process.
Contact: Julien LEROY - Senior Legal Adviser