9. Credit and financial institutions should put in place and maintain policies and procedures to …

Credit and financial institutions should put in place and maintain policies and procedures to comply with their obligations under Article 13(1) (a) and (c) of Directive (EU) 2015/849 in situations where the customer is onboarded remotely. These policies and procedures should be risk-sensitive and set out at least:

• a) a general description of the solution credit and financial institutions have put in place to collect, verify, and record information throughout the remote customer onboarding process. This should include an explanation of the features and functioning of the solution;
• b) the situations where the remote customer onboarding solution can be used, taking into account the risk factors identified and assessed in accordance with Article 8 (1) of the Directive (EU) 2015/849 and in the business-wide risk assessment, including a description of the category of customers, products and services that are eligible for remote onboarding;
• c) which steps are fully autonomized and which steps require human intervention;
• d) the controls in place to ensure that the first transaction with a newly onboarded customer is executed only once all initial customer due diligence (CDD) measures, have been applied;
• e) 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, the associated risks, and of the remote customer onboarding policies and procedures aimed at mitigating such risks.

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

3. Related Standards

• EBA - Published by the European Banking Authority at https://www.eba.europa.eu/