In late December, the ACPR published the final version of its revised guidelines on customer identification, ID verification and KYC aspects. The publication was informed by work done by the ACPR's AML/CFT Consultative Commission, of which AMAFI is a member.

The guidelines examine customer identification, ID verification and KYC obligations as well as obligations relating to information and document retention in the context of implementing AML/CFT arrangements. They are based on the legislative and regulatory provisions arising from transposition of Directive (EU) 2015/849 (revised in particular by the Fifth Anti-Laundering Directive) and the Executive Order of 6 January 2021, which reflects, among other things, the legislative amendments resulting from transposition of the directive.

The amendments include annex 10 on market transactions, which was published in March 2021 and to which AMAFI actively contributed. The changes involve ID verification measures and the new obligations relating to beneficial owners, the registry of beneficial owners and trust registries

AMAFI and other industry associations call on the ACPR to continue working on these guidelines, particularly those pertaining to beneficial owners (registry, notification of discrepancies, new obligations) and remote entry into a business relationship, especially in instances where the services of a remote ID verification service provider are employed.