FMA Guidelines Regarding "Remote Identification"

The FMA recently released guidelines for certain electronic means of identification when conducting remote identifications for the purpose of due diligence. This includes guidance related to video identification and other methods that are considered sufficient for remote identification. Consequently, this replaces the criteria of “physically present.”

The guidelines provide that video identification can be sufficient provided that there are no digital streaming interruptions, stating that these methods can still ensure the highest possible standard of due diligence.

This form of identification is sufficient for the identification of a natural person provided that the document used is a passport, photographs of the front and back or the document are taken, and there are multiple images taken of the document’s security features. Furthermore, a photograph of the person to be identified must be taken, which has to match the document with a less than 2% false acceptance rate. The accuracy of the data must be confirmed by the person identified, and finally, all of the identification process must be encrypted at state-of-the-art standards.

In the event of a natural person representing a legal entity, you need all of the aforementioned information for each beneficial owner, plus information regarding the entity itself. Furthermore, the executive body of the legal entity must in turn confirm that the identification of the beneficial owners is correct. This is a provision that can also be accomplished via video means so long as the executive body certifies this via video as well, meaning that the relevant form is signed on video.

Looking for more information on how to navigate these new regulations? If so, don’t hesitate to reach out to our office at


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