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EBA Guidelines for Remote Customer Onboarding

November 2022

The European Banking Authority (EBA) has published its final Guidelines on the application of anti-money laundering and countering the financing of terrorism (AML/CFT) rules where customers are onboarded remotely.

The EBA are aware that designed persons, as defined under the Irish Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended, have been experiencing a growing demand for remote customer onboarding solutions, especially due to the restrictions on movement caused by the COVID-19 pandemic and that there is not sufficient clarity and convergence about what is, and what is not, allowed in a remote and digital context.

The Guidelines therefore set out the steps credit and financial institutions should take when choosing remote customer onboarding tools and when assessing the adequacy and reliability of such tools, in order to comply effectively with their AML/CFT obligations. The guidelines are technologically neutral and do not prioritise the use of one tool over another.

These guidelines establish common EU standards on the development and implementation of sound, risk-sensitive initial customer due diligence policies, and processes which must be followed when customers are onboarded remotely.

A list indicating considerations which the above-mentioned internal policies and procedures should set out is also provided within the Guidelines and includes:

• the types of documents that are admissible and the information and authenticity checks that are necessary to identify the customer and verify their identity;

• the level of human intervention required in the remote verification process;

• the controls in place to monitor, on an ongoing basis, the correct and appropriate functioning of each remote customer onboarding solution and the effective implementation of the remote customer onboarding policies and procedures; and

• a description of the induction and regular training programs to ensure staff awareness and up-to-date knowledge of the functioning of the remote customer onboarding solution(s), the associated risks, and of the remote customer onboarding policies and procedures aimed at mitigating such risks.

To see learn more on how RegSol can assist your firm in implementing the EBA’s Guidelines and/or provide tailored AML training relevant to your firm, please do not hesitate to contact us at info@regsol.ie

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