Are institutions referred to in Section 1d(1) under (a) of the Anti-Money Laundering and Anti-Terrorist Financing Act (Wet ter voorkoming van witwassen en het financieren van terrorisme – Wwft) allowed to use electronic means of identification (eID tools) to verify customers’ identity in order to comply with the requirements of the Wwft?
Yes, if the eID tool used is sufficiently reliable. An eID tool is sufficiently reliable if it meets assurance level ‘substantial’ or ‘high’. These assurance levels are defined in the eIDAS Regulation. Institutions that consider accepting an eID in the context of carrying out the required customer due diligence measures must therefore determine themselves, or through a relevant expert, whether a specific eID tool is a sufficiently reliable means of identification as intended for this purpose.
Based on the Wwft, DNB has no role in testing specific eID tools against the assurance levels defined in the eIDAS Regulation prior to their use. Based on its powers under the Wwft, DNB monitors customer due diligence as part of its ongoing (and risk-based) supervision. On this basis, DNB may make risk-based assessments to establish whether institutions that use eID tools for customer identification and verification comply with the applicable conditions. This does not alter the fact that the institution remains responsible for complying with these conditions at all times.
This Q&A page pertains to the following statutory provisions:
De Nederlandsche Bank (DNB) issued an instruction on 29 September 2022 to trust office CIS Management B.V. (CIS) for serious deficiencies in its systematic integrity risk analysis (SIRA). DNB confirmed to CIS on 18 December 2023 that it had sufficiently complied with the instruction.
Read more Instruction issued to trust office CIS Management B.V. for serious shortcomings in its SIRA
There are two new regulatory developments of relevance to banks regarding their crypto asset exposures. Firstly, the Capital Requirements Regulation 3 (CRR3) includes a transitional regime on banks’ direct crypto asset exposures.
Read more New rules for the crypto exposures of banks
The final texts of the Capital Requirements Regulation 3 (CRR3) and the Capital Requirements Delegation 6 (CRD6) were published on 19 June 2024. With this new banking package, the final Basel 3 reforms are implemented in the European Union.
Read more Publication new banking package CRR3/CRD6
Liability-Driven Investment funds (LDI funds) mainly invest in long-term government bonds and long-term interest rate derivatives. The use of these interest rate derivatives exposes LDI funds to liquidity risks in case of large interest rate fluctuations.
Read more Limited liquidity risks in Euro LDI funds
