Digital Customer Onboarding Guidelines

Digital Customer Onboarding Guidelines

Digital onboarding is becoming increasingly important in the context of Anti-Money Laundering (AML) compliance.

The traditional manual process of onboarding customers can be time-consuming, costly and error-prone, making it difficult for businesses to comply with AML regulations. Digital onboarding, on the other hand, can help to automate and streamline the onboarding process, making it more efficient, accurate and secure and more customer focused.

Digital Onboarding tools can help to ensure that customers are who they claim to be, reducing the risk of fraud and money laundering. Digital onboarding can also help to improve customer due diligence (CDD).

Guidelines on Digital Customer Onboarding

1. Internal Policies and Procedures - Ensure the firm has specific policies and procedures concerning remote customer onboarding;
2. Obtaining Relevant Information - Identify natural persons, legal entities and the nature and purpose of the relationship. Understanding how the client intends to use the firms products or services provides insight;
3. Match Identity - use image capture, due diligence and live video (zoom, google meets etc) for customer identification;
4. Document Authenticity and Integrity - Verify the documents are authentic. Verify against the issuing body or initiate a live video to have the client present the document provided during onboarding; &
5. Screen Against Sanctions & Fraud Lists - including Global, Domestic and Internal Lists.

Each country's Anti-Money Laundering Act is unique and will vary across geography. Additionally, each sector governed by each act may have additional requirements prescribed by regulations. ‍‍

Typically, When undertaking standard Customer Due Diligence (CDD), you must obtain:
(a) the person’s full name; and
(b) the person’s date of birth; and
(c) if the person is not the customer, the person’s relationship to the customer; and
(d) the person’s address or registered office; and
(e) the person’s company identifier or registration number; and
(f) any information prescribed by regulations.

This should be completed for your customer, any beneficial owner of the entity and any person authorised to act on behalf of the customer. You must then take reasonable steps to verify this information to be satisfied it is correct.

You must also obtain information on the nature and purpose of the business relationship between you and the customer, as well as sufficient information to determine whether the customer should be subject to enhanced customer due diligence. This is an important part of Customer Due Diligence and assists you to assess the level of risk associated with a customer.

Avid AML obtains Standard Due Diligence information including customer nature and purpose making onboarding easier for you and your customer.

This is a general reference and does not take into account your firms Risk Assessment, Country or Sector specific regulations or code of practice. Your firms compliance manager will have conducted a Risk Assessment and will have outlined firm policy and developed the AML policies, procedures and controls suitable to the firm.
For additional resources refer to FATF Digital Identity information.