There is considerable interest in digital identities and their use as part of AML/CTF procedures, and an array of work being done in this field.
- JMLSG Guidance recognises the use of digital identity and electronic verification of identity and provides some guidance on criteria that may assist firms when considering using these processes. The government’s guidance on identity checking is an additional criterion that may be helpful for firms when exercising their own judgment in these instances (per 5.3.52).
- The Department for Digital, Culture, Media and Sport (DCMS) is also in the process of establishing the UK’s digital identity and attributes trust framework, which will be underpinned by the necessary legislative and regulatory mechanisms. The intention includes recognition of the status of digital identities and ensuring digital identity providers are vetted and governed appropriately.
JMLSG continues to monitor the regulatory framework governing AML/CTF to ensure that the Guidance assists in interpreting regulatory obligations in an appropriate and pragmatic manner, including within the digital identity arena.