Dear clients and cooperation partners,
On 26 October 2016 the Lithuanian Government amended its Resolution establishing client identity verification methods. The amendments establish additional methods for remote identification. The amended Resolution will come into effect on 1 December 2016.
REMOTE IDENTITY VERIFICATION
Under the amended Resolution, remote identification will be possible in the following ways:
- When information about a person’s identity is certified by a qualified electronic signature which complies with the requirements of Regulation (EU) No 910/2014.
- When information about a person’s identity is confirmed by electronic identification means issued in the European Union and functioning under electronic identification schemes with high or substantial assurance level under Regulation (EU) No 910/2014.
- Using electronic means, allowing direct view transmission, in one of the following ways:
- identity document or residence permit in Lithuania captured using video-streaming and identity confirmation using at least an advanced electronic signature, meeting the requirements of Regulation (EU) No 910/2014;
- client’s facial image and original identity document or residence permit in Lithuania captured using video-streaming.
Detailed arrangements for the use of electronic means for video-streaming will be confirmed by the Financial Crime Investigation Service by 1 December 2016. However, it is already certain that transmitting both videos and photographs using above mentioned means will be allowed. There will be a requirement for video-streaming to be direct and live, which means that videos or photos not taken during live video-streaming will not be accepted. Consolidation of new means for remote client identity verification is one more step towards establishing Lithuania as a preferred jurisdiction for FinTech companies.
USE OF NEW IDENTITY VERIFICATION METHODS
Financial institutions and other legal entities that will use the new remote identification methods must update their internal money laundering and terrorist financing prevention procedures and/or rules. Please note that financial institutions that have submitted their internal money laundering and terrorist financing prevention procedures and/or rules to the Bank of Lithuania during their licensing procedures must submit revised and supplemented/amended documents to the Bank of Lithuania for information purposes.
Law firm Sorainen was actively involved in providing suggestions for amending the Resolution and creating rules for the Financial Crime Investigation Service covering use of electronic means allowing direct view transmission. Sorainen associate Artūras Asakavičius suggested several remote identification concepts, which were successfully implemented in the law. |