The objective of this project was to identify the degree of interoperability between the Government’s Good Practice Guide 45: Identity Proofing and Verification of an Individual (GPG45) and the Joint Money Laundering Steering Group (JMLSG) Guidance Notes, and to identify any requirements to create an interoperable framework.
GPG45 provides the standards for the manner in which digital identities are created and used for accessing services. It has been recently updated, which introduced a number of changes, and is intended to apply to not only digital identities used in the public sector, but also the private sector. JMLSG Guidance Notes on the other hand provides detailed guidance to financial services organisations, as well as a wide range of other regulated industries, and covers the manner in which organisations can meet their anti-money laundering obligations through their customer due diligence processes.
If GPG45-aligned digital identities can meet the expectations set out in JMLSG Guidance, and the two sets guidance can interoperate, this could pave the way for digital identity use by the financial services sector.
The paper identifies wide-ranging alignment, alongside a number of specific areas where challenges exist, and where amendment and further alignment may be necessary. The report also looks towards the implementation of the 5th Money Laundering Directive, and other issues that may need further consideration for interoperability and the evolution of standards in future, such as the creation of industry-specific identity profiles, and the codification of ‘trusted events’.