This Guidance focuses on the use of digital ID systems for CDD, specifically for customer identification and verification at onboarding or account opening and for ongoing CDD monitoring, thus enabling LFIs to fulfill their obligations under Articles 8 and 7, respectively, of the AML-CFT Decision. The Guidance emphasizes, however, that customer identification and verification and ongoing monitoring of the business relationship are only two components of LFIs’ wider CDD obligations, which include identifying and verifying the identities of a legal entity customer’s beneficial owners and understanding the nature of the customer’s business and the nature and purpose of the customer’s business relationship with the LFI. LFIs are also separately required under Article 24 of the AML-CFT Decision to maintain all records and documents obtained through CDD measures for a period of no less than five years from the date of termination of the business relationship with the customer; under FATF standards and UAE regulation, such recordkeeping requirements are technology neutral, meaning they apply equally to records kept in digital and physical (documentary) form.

The Guidance focuses primarily on identity proofing and enrollment and secondarily on authentication; it does not address portability and interoperability, as these components are regarded as optional under international AML/CFT standards and are less directly relevant to the application of CDD measures by LFIs. Particular emphasis will be placed on the use of third-party sources or providers to verify and authenticate customer identity through digital means.

Finally, the Guidance focuses on the use of digital ID systems to identify and verify the identity of customers that are individuals (natural persons). It does not examine the use of digital ID systems to help identify and verify the identity of a legal person’s representative(s) or beneficial owner(s) or to understand and obtain information on the nature and intended purpose of the business relationship—although reliable, independent digital ID systems are important for all of these CDD functions.