Insurance and Pensions Denmark (F&P) would like to thank the Euro-pean Banking Authority to publish and to invite for feedback on the draft guidelines on remote customer on-boarding, which we understand will be applicable to the sector in general further to their obligations under the AML regulation.

We find these draft guidelines an important step for the further digitali-zation of the sector and the growing of remote customer onboarding beyond the Covid 19 era, as it is more time effective.

The guidelines are well-balanced and neutral to technology, which is important for further digitalization.

Our main concern is to make certain, that the guidelines properly reflect more lenient requirements to part of the sector, where the risk of mon-ey laundering is particularly low, as for instance occupational pensions schemes. Hence it should be clear from the guidelines, that for low-risk companies, it should be sufficient to fulfill the identification obligations (no further requirements) within the AML regulation, to use nationally approved digital identities.