The IBFed commented on the guidance proposed by the Financial Action Task Force (FATF), aimed at helping governments, financial institutions and other relevant entities to apply a risk-based approach to the use of digital ID for customer due diligence.

In the letter we explain that consistency with global standards is important; financial entities should not be solely responsible for assessing the assurance level of the digital ID systems. We recommend to include reference to market resilience considerations and we advocate for a balance between the AML/CFT requirements and financial inclusion objectives. Finally, we would support inclusion of wider AML/CTF use cases than identification and authentication of natural persons.

IBFed letter to FATF_Digital Guidance_6 December 2019

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