Filed Under: Banking and Finance, Finance and Banking, Identification and Authentication, Identity, Political, legal and regulatory, Public Sector and NGO, Public Sector and NGOs

AMLD4.1, AMLD5 or 5AMLD?

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I recently came across a statistic that surprised me.

Approximately 50% of new bank accounts are opened by customers that have recently arrived in the UK to work or study.

http://www.openidentityexchange.org/wp-content/uploads/2016/10/Digital-Identity-Across-Borders-FINAL-Feb2016-2.pdf

I had wrongly assumed that the majority of new bank accounts openings in the UK would be from students just about to go off to University, like my son, and that migration whilst high (as the media keeps telling us) would still be a minority. But based on some back-of-the-envelope calculations it appears that the 50% number is about right.

As the OIX report above points out, these new arrivals in the UK are very difficult to perform KYC (“Know Your Customer”) on due to the lack of data. They have no history in the UK. This is exactly where eIDAS should be able to step in. For example, a person arriving from France should be able to use their French government-issued eID as one piece of evidence to help meet KYC requirements. The proposed new AML legislation – the amendment to the fourth AML directive – which I have seen referred to as AMLD4.1, AMLD5 and 5AMLD, explicits call out to eIDAS as a potential solution.

There are however some issues with this:

Firstly, to become part of the eIDAS scheme, governments have to “notify” their eIDs into the scheme. To date only Germany has done so.

Secondly, eIDAS provides a switching infrastructure that makes all eIDs interoperable but initially this will only available to the public sector. If a private sector organisation, such as a bank, wishes to leverage an eID it will need to find another way to access or read it.

Thirdly, the mobile channel is becoming increasingly important with banks needing to be able to onboard customers directly in that channel, as well as performing identification and verification of existing customers when provisioning a mobile app. Several of the existing eIDs are smart-card based. These will only be readable by phones if the cards themselves are contactless (which many of them are). They will not however be readable on iPhones, even with the limited opening up of the NFC interface expected in iOS11.

There is clearly therefore a need for some alternative mobile based technology. Fortunately such technology exists in the form of mobile document and selfie capture and verification. One of the vendors in this space, Mitek, kindly commissioned Consult Hyperion to write a paper on this very topic which I had the privilege of presenting at Money2020 last week. You can download the paper here:

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