Regulatory Alerts2014-09-26 | Circular 7/2014 (GW) - Scanning fulfils record-keeping obligation pursuant to section 8 (1) sentence 3 of the GwGBaFin Circular 7/2014 (GW): Scanning Identity Verification Documents Fulfills Record-Keeping Obligations
BaFin confirms that scanning documents presented for identity verification under the GwG fulfills the statutory record-keeping obligation. Regulated financial entities, including credit institutions, payment service providers, and investment management companies, must implement appropriate technical and organizational measures to securely store the scanned data. This administrative practice applies to all identity verification documents under sections 4(4) sentence 1 numbers 1 and 2, effectively modernizing compliance procedures while maintaining substantive legal requirements.
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