What we recently published.
Regulatory updates and case notes on DNB, AFM, EBA, ESMA and the European Commission — always with a practical lens for payment institutions, EMIs, investment firms and fintechs. Follow our LinkedIn page for shorter updates in between.
Our three most recent publications.
Straight from our LinkedIn page. Click through for the full post and the discussion underneath.
A selfie-and-ID check is no longer “remote verification”
AMLA has finalised its CDD standards. A selfie-and-ID check is now an “alternative solution”. The first routes are showing the document in person, or eID. Article 7 applies only if the customer can reasonably do neither. You must record, customer by customer, why eID was not possible. A vendor default is not a reason. The RTS under Article 28(1) AMLR is not yet adopted by the Commission.
Model portfolio: self-directed investing or portfolio management?
The AFM is consulting on “Model portfolios within self-directed investing”, with 19 questions. You can respond until 11 November. It is explicitly not an AFM position. A model portfolio stays self-directed if the investor decides. The firm has no discretion and gives no personal recommendation. Fix rebalancing and de-risking rules in advance, per instrument. The AFM also wants to withdraw its 2016 Guidance.
A virtual IBAN is not a shortcut around CDD
From 10 July 2027, whoever issues a virtual IBAN must know who is behind it. Article 22(3) AMLR requires identifying and verifying every user and the associated account. AMLA finalised its CDD standards on 1 October 2026. Link every virtual IBAN to a verified user. Test the five-working-day answer. Store account opening and closing dates against each virtual IBAN.