Within the DINNOCAP project, the Ministry of Economic Affairs and Communications of Estonia together with the Estonian Chamber of Commerce and Industry surveyed obliged entities to assess the attitudes towards the implementation of know your customer (KYC) procedures.
At the end of 2021, the information about the survey was published on the website of the Chamber of Commerce and Industry and forwarded to more than 3500 members of the Chamber in Estonia. Three financial institutions, five companies providing legal services, and eight companies providing accounting services responded to the questionnaire.
Following conclusions can be drawn from the survey:
The low completion rate of the survey may indicate that many companies and entrepreneurs are unaware that they are obligated within the meaning of the AML regulations.
Companies that have an AML/KYC specialist perform KYC with more thoroughness. They collect and verify data via various sources.
Obliged entities consider that access to data in national registers and databases. The cost of obtaining such data (e.g. state fees) is an obstacle when conducting KYC, as well as the fact that the data is not in a machine-readable format.
Obliged entities trust data in national registers and databases, as well as data that is directly transmitted or digitally signed by customers themselves.
Obliged entities consider that they do not have sufficient knowledge of where and how to collect data for performing KYC procedures.
Obliged entities expect AML guidelines to be more understandable.
Obliged entities expect data in national registers and databases to be available in a machine-readable format.
Obliged entities except for procedures for conducting KYC to be automated and standardized with uniform principles in the EU.
Obliged entities consider that AML regulations and rules are too strict compared to neighboring countries and directly restrict their everyday business. They feel that the state does not pay enough attention to facilitating the implementation of anti-AML regulations and KYC procedures.
Obliged entities would prefer a state-recognized KYC service that uses data from national registers and databases.
Obliged entities consider that the KYC service recognized by the state should be based on a data set / KYC profile containing a minimum list of questions, documents, and data to be collected to perform KYC procedures. Also, they believe that the state should verify the data they have in their national registers. The person, subject to the KYC, should have an access to information on who has requested and used his or her KYC data for what purpose.
Individuals agree to give consent (so-called consent management) to obliged entities for automatically receiving their KYC data in a machine-readable format.
The full summary of the survey can be found: