On May 7, ISDA responded to the Anti-Money Laundering Authority’s (AMLA) consultation on draft regulatory technical standards (RTS) on customer due diligence under the Anti-Money Laundering Regulation (AMLR). In the response, ISDA endorsed the Association for Financial Markets in Europe’s response to the consultation but also highlighted inconsistencies in the standards of identification and verification required for senior managing officials of a customer and other representatives of the customer that might be less senior.

The draft RTS allows the address of the registered office of the legal entity to be obtained instead of the senior managing official’s residential address and country of residence. However, under the draft RTS, full residential address details must be obtained for an employee of the customer that acts on behalf of that customer and is less senior within the organization, such as an authorized signatory. ISDA’s response proposes an amendment to Article 16 of the draft RTS that would resolve this inconsistency.