Topic starter
25/10/2026 11:10 am
TL;DR: AMLA’s final RTS draft for customer due diligence lets eID and qualified trust services work in every channel, narrows remote document verification to justified exceptions, and requires missing attributes to be filled before onboarding can be treated as complete, according to IDnow. That pushes identity teams toward one governed verification flow, not separate branch and digital exceptions.
Editorial analysis by NHI Mgmt Group, based on content published by IDnow: “AMLR CDD RTS: what the final draft changes for your onboarding”.
Key questions
Q: How should firms govern customer onboarding when multiple identity verification routes are allowed?
A: Treat the routes as one governance model, not three separate processes.
Q: Why do exception-based verification flows create compliance risk?
A: Exception-based flows create risk when eligibility is informal, evidence is incomplete, or supervisors cannot reconstruct the decision later.
Q: What should teams do when identity attributes are missing from a compliant verification flow?
A: Do not treat missing attributes as a manual afterthought.
Practitioner guidance
- Map every onboarding route to one approved verification policy Document which journeys use identity documents, eID, qualified trust services, or the narrow remote document exception, and make the approval criteria explicit.
- Build case-level justification for remote document use Capture the reason the customer could not reasonably use the standard route and retain the supervisory evidence needed to defend each exception.
- Compare collected attributes to the required minimum set Check names, birth data, nationality, residence, and tax identification coverage, then define a governed process for filling any missing attribute.
Bottom line: The article shows that regulated onboarding is moving from channel-based verification to a single governed decision model.
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