FINMA publishes partially revised circular on "video and online identification”

Dr. Günther Dobrauz Partner and Leader Legal, PwC Switzerland 18 Jul 2018

From 13 February 2018 to 28 March 2018 the Swiss Financial Market Supervisory Authority FINMA conducted a public hearing on the draft of the partially revised FINMA Circular 2016/7 "Video and online identification". FINMA published the partially revised circular on 17 July 2018. The aim of the partial revision is to adapt the Circular to the technological innovations and to the experience gained in applying the Circular since it entered into force in March 2016.

The revised FINMA Circular entails the following changes:

A. Video identification

  • The identity of the contracting party does no longer need to be verified by means of a TAN (transaction number) or a similar method.
  • The video identification process does no longer need to be cancelled if there are indications of higher risks. However, it must be ensured that the client will be onboarded only when the the approval of a supervisor, a superior or the management board has been granted.

B. Online identification

  • The financial intermediary can use technical means to compensate for difficult lighting conditions during identification. 
  • The online identification process may be continued with the consent of a supervisor, a superior or the management board if there are indications of higher risks. 
  • Only official identification documents with an MRZ (Machine Readable Zone) and optical security features (e.g. holographic-kinematic features or printing elements with a tilting effect) may be used for identification.
  • The authenticity of the identification document must be verified using at least two randomly selected security features. In addition, the financial intermediary must ensure that a photograph has been taken of all relevant pages of the identification document.    
  • For money transfers, instead of an account with a bank in Switzerland or Liechtenstein, a bank in a member state of the Financial Action Task Force (FATF) is now sufficient, provided that the country concerned has not been rated non-compliant” or “low” as part of the country audit. 
  • The residence address can now also be verified with a tax or other official invoice.

C. Compliance check

  • The compliance check with FINMA Circular by recognised supervisory audit firms is repealed.

What's next?

The amendments to the new FINMA Circular become immediately effective. The financial intermediaries concerned will be granted a transitional period until 1 January 2020 for the process adjustments. 

FINMA will continue to follow technological developments with regard to video and online identification and reserves the right to adapt the circular again if necessary.


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Dr. Günther Dobrauz

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Dr. Jean-Claude Spillmann

Partner, Head Asset & Wealth Management and Banking Regulatory, Legal, Zurich, PwC Switzerland

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