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Q&A Electronic means of identification and client identification

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Question:

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?

Answer:

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.

Relevant laws and regulations

This Q&A page pertains to the following statutory provisions:

  • Section 11(1) of the Wwft: If the customer, the settlor of a trust, the trustee of a trust, the partner of a partnership or the person authorised to manage the partnership is a natural person, his identity shall be verified on the basis of documents, data or information from a reliable and independent source. Documents, data or information that may be used to comply with the provisions of the preceding sentence may be designated by ministerial regulation.

  • Section 4(1), under H, of the Regulation implementing the Wwft: The following documents are designated as documents that meet Section 11(1) first sentence of the Act: (...) a sufficiently reliable means of identification.

  • The eIDAS Regulation (Regulation (EU) 910/2014)

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