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Response to consultation on proposed RTS in the context of the EBA’s response to the European Commission’s Call for advice on new AMLA mandates
Go backQuestion 1: Do you agree with the proposals as set out in Section 1 of the draft RTS? If you do not agree, please explain your rationale and provide evidence of the impact this section would have, including the cost of compliance, if adopted as such?
Data points in relation to place of birth of natural persons - see also art. 3 and art. 5: The current draft RTS specifies that "place of birth" constitutes of city and country of birth, and that a document eligible for verification of identity MUST contain this information.
Certain countries do however NOT include information on place of birth in official identification documents, e.g.,
- Switzerland (compare information in PRADO): Both national ID card and passport contain "place of origin", which in most cases is NOT the place of birth, but the municipality that granted citizenship. To my knowledge, there is no proof-of-identity document available to Swiss citizens containing this information;
- United States of America: U.S. passports contain information on country and state of birth, but NOT city of birth.
Impact if requirement will not be changed: For certain nationalities, obliged entities will not be able to meet the minimum requirements for verification, given that there is no available identity document based on national rules.
Proposal: Information on place of birth (country and city) shall be collected as part of CDD, but a verification of this piece of information shall only be subject to verification if the information is available. The requirement that a POI document MUST contain information on place of birth should accordingly be waived (also from art. 5 (2) as minimum requirement).Name of the organization
Saxo Bank A/S
