Video verification of a customer – Polish regulator KNF announces market audit of supervised entities

In accordance with the position of KNF, the introduction of automatic video verification system is acceptable, provided that a number of requirements are met. In particular, video verification is fully automated, i.e. carried out without the participation of an employee of the obligated institution at the stage of submitting a request for establishing a relationship by the customer. In addition to the requirements common to all types of video verification described in one of the previous articles (LINK), the KNF lists specific requirements:

1. strict definition of the criteria for the automated on-boarding process,
2. specification of situations in which automatic verification must be confirmed or supplemented by an employee of an obligated institution,
3. to provide a manual check by an employee of the obligated institution of at least some of the customers’ requests for establishing relationships, including in terms of the correctness and quality of video recordings – „conversations” (random checks).

At the same time, KNF recommends the use of complementary techniques, such as:

1. performing an OCR scan of an ID card (identity card, passport, residence card),
2. the use of biometric techniques, e.g. a comparison of the customer’s face with the image on the identity document,
3. using a sufficiently high compliance threshold for the biometric test,
4. taking a face photo of the customer from the mobile application used by the obligated institution

The observation of the Polish market of payment and banking services leads to the conclusion that changes in the distribution model of these are inevitable. Customers increasingly use mobile apps and expect from their service providers not only apps availability, but also full functionality. It is praiseworthy, that KNF is keeping pace with the rapidly changing economic reality.

We invite you to contact our Law Firm, which offers services such as:

1. legal design of customer identification systems and verification of their identity,
2. developing internal procedures of obligated institutions in the field of counteracting money laundering and financing of terrorism, including procedures of video verification systems. Video verification of a customer – Polish regulator KNF announces market audit of supervised entities