Regulatory Alerts2017-04-10 | Circular 3/2017 (GW) - video identification proceduresCircular 3/2017 (GW) – Requirements for Video Identification Procedures
The German Federal Ministry of Finance, via the Federal Financial Supervisory Authority (BaFin), issues Circular 3/2017 to establish comprehensive requirements for video identification procedures under the German Money Laundering Act. The circular mandates real-time, end-to-end encrypted video chats conducted by trained employees who must verify specific optical security features of identity documents and obtain explicit customer consent. It replaces prior guidance by requiring full audio-visual recording retained for five years, thereby enhancing security while maintaining practical feasibility for supervised financial entities.
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