Art. 32 Electronic identification means and relevant qualified trust services | RTS on customer due diligence | AML

This article governs how obliged entities must use electronic identification means and qualified trust services when identifying and verifying customers and beneficial owners.

It acts as a bridging article, connecting the practical use of digital identification tools to the attribute requirements set out in Annex I and the due diligence obligations established in Articles 20 and 22 of Regulation (EU) 2024/1624.

The level of attributes required from these tools scales with the due diligence level being applied, whether simplified, standard, or enhanced.

Crucially, where a digital tool falls short of covering all required attributes, obliged entities must fill the gap through other means.

Important points:

Ensure that electronic identification means and qualified trust services used for customer verification carry the attributes specified in Annex I, matched to the applicable level of due diligence.
Where a digital identification tool does not cover all required attributes, take steps to obtain and verify the missing attributes through other means in line with Article 22(6) of Regulation (EU) 2024/1624.
Additional attributes or enhanced measures, including higher assurance levels or combining identification means with qualified trust services, may be applied where justified by the ML/TF risk associated with the customer or beneficial owner.

1. Annex I defines the corresponding list of attributes that electronic identification means and qualified trust services are required to feature in accordance with Article 22(6), point (b), of Regulation (EU) 2024/1624, in order to fulfil the requirements of Article 20(1), points (a) and (b), and Article 22(1) of that Regulation, for the purposes of applying standard and enhanced due diligence measures. Where simplified due diligence is to be applied, the electronic identification means and relevant qualified trust services shall have the corresponding attributes laid down in Annex I that allow compliance with Section 5 of this Regulation.
1. Obliged entities may consider featuring additional attributes to assist the unambiguous identification and verification of the customer or beneficial owner if justified by the ML/TF risk associated with the customer or beneficial owner.
1. Where an electronic identification means or qualified trust service does not possess all attributes that allow the identification and verification of the customer or beneficial owner, as required in Article 22(1) of Regulation (EU) 2024/1624 or Section 5 of this Regulation, the obliged entity shall take steps to obtain and verify the missing attributes through other means in line with Article 22(6) of Regulation (EU) 2024/1624.
1. Obliged entities may consider putting in place enhanced measures to complement the mitigation of ML/TF risks, including the use of higher assurance levels or complementing electronic identification means with qualified trust services.