KYC industry standard

On 31 May 2024, the EU legislator adopted a legislative package to combat money laundering. The new provisions are due to come into force on 10 July 2027. At the heart of the legislative package, which comprises four regulatory strands, is the Anti-Money Laundering Regulation 2024/1624. Articles 19 to 26 of this Regulation set out the requirements for customer identification and the collection of data on beneficial owners (‘Know Your Customer’). These new provisions are of particular importance for practi-cal implementation, especially within credit institutions.

The provisions of the legislative package are set out in detail by a large number of delegated acts within the meaning of Articles 290 and 291 TFEU, the majority of which are not yet available. Furthermore, many questions of interpretation arise regarding the legal terms used in the Anti-Money Laundering Regulation. These must be resolved in the short term to ensure timely implementation. Against this background, the Money Laundering Compliance Officers´ Working Group of the Association of German Banks (BdB) has drawn up an industry standard for questions of interpretation concerning customer identification and the collection of data to determine beneficial owners – the BdB KYC Industry Standard AMLR. The document, which is available for download in German and English, has been sent to various competent authorities and other stakeholders at national and EU level.

The interpretations contained therein reflect the state of knowledge at the time of its drafting (September 2926). Should further regulation result in changes to the KYC Industry Standard, these will be re-ported here.