Client identification requirements now more flexible
Jurisdiction – ESTONIA
Until recently, credit institutions and other financial institutions had to, upon opening an account or upon the first use of another service, identify the person participating in the transaction or using the service while being present at the same place as the person or the person’s representative (face-to-face identification).
As of 18 May 2012, financial institutions which are supervised by the Estonian Financial Supervision Authority may identify natural persons with whom they have no previous business relationship on the basis of a document issued by the Republic of Estonia for the purpose of digital identification, provided that until further due diligence measures have been taken:
1) the transactions are only domestic money transfers not exceeding 2,000 euros in total per month;
2) no authorization or identification services with regard to that person will be provided to third parties.
The new law does not require face-to-face identification also if the person entering into a business relationship with the financial institution has been identified by another financial institution. In such a case, written documents received from the other financial institution will suffice. In certain circumstances, face-to-face identification is also not necessary when financial institutions enter into business relationships among themselves.
If upon entering into a business relationship a person has been identified without being present at the same place with the person, further due diligence measures will have to be implemented later on.