EBA publishes guidelines on remote customer onboarding

The European Banking Authority (EBA) today published its final Guidelines on the use of remote customer onboarding solutions. These Guidelines set out the steps credit and financial institutions should take to ensure safe and effective remote customer onboarding practices in line with applicable anti-money laundering and countering the financing of terrorism (AML/CFT) legislation and the EU’s data protection framework. The Guidelines apply to all credit and financial institutions that are within the scope of the Anti-money Laundering Directive (AMLD).

These Guidelines establish common EU standards on the development and implementation of sound, risk-sensitive initial customer due diligence policies and processes in the remote customer onboarding context. They set out the steps 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.

Legal basis and background

These 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 and terrorism financing (ML/TF).

The Anti-money Laundering Directive sets out what financial institutions should do to comply with their AML/CFT obligations but it does not set out in detail what is, and what is not, allowed in a remote and digital context, when onboarding new customers. This has created risks where regulatory expectations of credit and financial institutions’ remote onboarding practices were unclear. It has also made the uptake of new or innovative forms of customer identification by credit and financial institutions more difficult. These risks and challenges were amplified by increasing demand for non-face-to-face customer take-on options during the Covid-19 pandemic.