On 22 November 2022, EBA issued guidelines outlining the procedures for credit and financial institutions to follow in order to comply with their due diligence obligations for remote customer onboarding under AML/CFT legislation. These guidelines (EBA/GL/2022/15) encompass steps for institutions when relying on third-party services and the establishment of CDD procedures for remote CDD measures. The effective date for these guidelines is set for 2 October 2023, applying to credit and financial institutions defined in Article 3 of Directive (EU) 2015/849.
The AMF has therefore incorporated these guidelines into its framework by issuing DOC-2023-07, expanding their scope to entities falling under the AMF’s supervision for AML/CFT purposes, including asset management firms, collective investments, and financial investment advisors. Hence, from 2 October 2023, credit and financial institutions must adhere to these guidelines.
Concurrently, the AMF has updated its position-recommendation DOC-2019-16 (Guidelines on client due diligence) to reference the EBA’s guidelines, thereby ensuring consistency and clarity in AML/CFT compliance procedures.