FAQ on AML/CFT and IT requirements for specific customer onboarding/KYC methods for the identification/verification through video chat is a CSSF FAQ, published 8 March 2018.
\nRelevant for: AISPs, Central Securities Depositories (CSDs), Consumer protection, Credit institutions, Credit servicers, Data Reporting Service Providers (DRSPs), E-money institutions, Investment firms, Investment funds and vehicles, Other specific authorisations, registrations and information, Part II UCIs, Payment institutions, Payment institutions/electronic money institutions/AISPs, Pension funds, SICARs, SIFs, Specialised PFS, Support PFS, UCITS, Virtual asset service providers (VASPs).
\nMain topic: Financial crime. Keywords: AML/CFT, Customer onboarding, Financial innovation.
\nFrequently asked questions on AML/CFT and IT requirements for specific customer on-boarding/KYC methods
\nFREQUENTLY ASKED QUESTIONS ON AML/CFT AND IT REQUIREMENTS FOR SPECIFIC CUSTOMER ONBOARDING/KYC METHODS
\nFrequently asked questions on AML/CFT and IT requirements for specific customer on-boarding/KYC methods TABLE DES MATIÈRES / TABLE OF CONTENTS Question 1: What is meant by “Identification/Verification of identity through video chat”? Question 2: Who can perform the video identification? Question 3: Who is responsible for respecting the professional obligations as required by the Luxembourg AML/CTF regulations? Question 4: Who are the persons that can be identified/verified through the online video conference? Question 5: In what circumstances is the video identification not possible? Question 6: What are other preliminary measures that have to be taken prior to the beginning of the process of the video identification? Question 7: What is the contribution of the customer in the context of the video identification? Question 8: What are the necessary data quality conditions to be observed during the identification process? Question 9: What are the professional’s obligations in case a problem occurs during the video identification process? Question 10: What are the customer data record/retention obligations of the professional? Question 11: What are the customer data record/retention obligations of the external provider? Question 12: What kind of additional security measures should be taken by both the professional and the external provider? Question 13: Are there any special conditions regarding data protection requirements? Question 14: May AML/CFT obligations of the professional other than the identification/verification of identity of the customer be performed through an online video conference with the customer? Question 15: What is the role of the CSSF with respect to external providers of video identification (automated or not) tools? Question 16: What type of activities related to customer due diligence for AML/CTF purposes would require a licence as a professional of the financial sector in Luxembourg?
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\nFREQUENTLY ASKED QUESTIONS ON AML/CFT AND IT REQUIREMENTS FOR SPECIFIC CUSTOMER ONBOARDING/KYC METHODS
\nQuestion 1: What is meant by “Identification/Verification of identity through video chat”? 8 April 2016
\nBy “Identification/Verification of identity through video chat” (hereafter “video identification”), the CSSF means the performance of the identification/verification of the identity of the customer by a professional of the financial sector under the supervision of the CSSF (hereafter the “professional”) through an online video conference. The professional uses this process in order to support and execute certain tasks for the purpose of fulfilling his customer identification and verification of identity obligations as required i.a. by the Law of 12 November 2004 on the fight against money laundering and terrorist financing (“the Law”). Notwithstanding this possibility, it shall be stressed that all other anti-money laundering and counter-terrorist financing (“AML/CTF”) professional obligations (e.g. requirements with respect to AML/CTF outsourcing (if applicable), adequate training, internal controls, suspicions reporting, etc.) will have to be strictly applied by the professional.
\nQuestion 2: Who can perform the video identification? 8 March 2018
\nThe professional has the following possibilities: i)
\nPerform the video identification process himself using a tool developed internally, or
\nii)
\nPerform the video identification process himself using an external tool he has acquired from an external provider, or
\niii)
\nDelegate the identification process to an external provider using his own tool.
\nIn each of these scenarios, the video identification needs to be performed by a specifically trained employee, either of the professional or, if applicable of the external provider.
\nThe text above is the opening of the document; the PDF carries the whole.
\nDocument page, PDF. Source: Commission de Surveillance du Secteur Financier (CSSF), reproduced with the CSSF's consent. The French text prevails.
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