The IIF submitted comments on the FATF digital identity draft guidance. We strongly support the FATF’s efforts to address how digital identity systems can be used for customer due diligence. However, topics such as the use of multiple reliable ID sources, creating interoperable digital IDs, and ensuring personal information security are some of the areas where there is opportunity for the guidance to be further and dynamically updated by the FATF in order to remain relevant in this increasingly transforming space. 

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