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DIGITAL IDENTITYMARCH 2020

The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotespolicies to protect the global financial system against money laundering, terrorist financing and the financing ofproliferation of weapons of mass destruction. The FATF Recommendations are recognised as the global anti-moneylaundering (AML) and counter-terrorist financing (CFT) standard.For more information about the FATF, please visit www.fatf-gafi.orgThis document and/or any map included herein are without prejudice to the status of or sovereignty over anyterritory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area.Citing reference:FATF (2020), Guidance on Digital Identity, FATF, ital-identity-guidance.html 2020 FATF/OECD. All rights reserved.No reproduction or translation of this publication may be made without prior written permission.Applications for such permission, for all or part of this publication, should be made tothe FATF Secretariat, 2 rue André Pascal 75775 Paris Cedex 16, France(fax: 33 1 44 30 61 37 or e-mail: contact@fatf-gafi.org)Photocredits coverphoto Getty Images

GUIDANCE ON DIGITAL IDENTITYTable of ContentsACRONYMS . 3EXECUTIVE SUMMARY . 5SECTION I: INTRODUCTION . 13SECTION II: DIGITAL ID TERMINOLOGY AND KEY FEATURES . 17SECTION III: FATF STANDARDS ON CUSTOMER DUE DILIGENCE . 27SECTION IV: BENEFITS AND RISKS OF DIGITAL ID SYSTEMS FOR AML/CFTCOMPLIANCE AND RELATED ISSUES . 35SECTION V: ASSESSING WHETHER DIGITAL ID SYSTEMS ARE SUFFICIENTLY RELIABLEAND INDEPENDENT UNDER A RISK-BASED APPROACH TO CDD . 47APPENDIX A: DESCRIPTION OF A BASIC DIGITAL IDENTITY SYSTEM AND ITSPARTICIPANTS . 59APPENDIX B: CASE STUDIES . 71APPENDIX C: PRINCIPLES ON IDENTIFICATION FOR SUSTAINABLE DEVELOPMENT . 87APPENDIX D: DIGITAL ID ASSURANCE FRAMEWORK AND TECHNICAL STANDARDSETTING BODIES . 91APPENDIX E: OVERVIEW OF US AND EU DIGITAL ASSURANCE FRAMEWORKS ANDTECHNICAL STANDARDS . 93GLOSSARY . 101 FATF/OECD 2020 1

2 GUIDANCE ON DIGITAL IDENTITY FATF/OECD 2020

GUIDANCE ON DIGITAL IDENTITYACRONYMSAAL 1/2/3Authentication Assurance Level (under NIST)ALAssurance LevelAML/CFTAnti-money laundering/Countering the financing of terrorismAPIApplication Programming InterfaceASPAuthentication Service ProviderCDDCustomer Due DiligenceCENEuropean Committee for StandardizationCENELECEuropean Committee for Electrotechnical StandardizationCSPCredential Service ProviderDCSDocument Checking ServiceDLTDistributed Ledger TechnologyDNFBPDesignated Non-Financial Businesses and ProfessionsETSIEuropean Telecommunications Standards InstituteeIDASRegulation (EU) N 910/2014 on electronic identification and trust servicesfor electronic transactions in the internal marketFAL 1/2/3Federation Assurance Level (under NIST)FIDOFast Identity OnlineGDPRGeneral Data Protection RegulationGPSGlobal Position SystemGSMAGlobal System for Mobile CommunicationsICTInformation and communications technologyIAL 1/2/3Identity Assurance Level (under NIST)IDIdentityIDSPIdentity Service ProviderIECInternational Electrotechnical CommissionINR.Interpretive Note to RecommendationIPInternet ProtocolISOInternational Organization for StandardizationITUInternational Telecommunications UnionIVSPIdentity Verification Service ProviderLoALevel of AssuranceMACMedia Access ControlMLMoney launderingMFAMulti-factor authenticationNGONon-governmental organisationsNISTNational Institute of Standards and TechnologyOIDFOpenID FoundationPIIPersonally Identifiable InformationPINPersonal Identification NumberR.RecommendationRBARisk-based approach FATF/OECD 2020 3

4 GUIDANCE ON DIGITAL IDENTITYSAGStandards Advisory GroupSCAStrong Customer AuthenticationTFTerrorist financingVASPVirtual Asset Service ProvidersW3CWorld Wide Web ConsortiumUNHCRUnited Nations High Commissioner for Refugees FATF/OECD 2020

GUIDANCE ON DIGITAL IDENTITY 5EXECUTIVE SUMMARY1.Digital payments are growing at an estimated 12.7% annually, and are forecast toreach 726 billion transactions annually by 2020.1 By 2022, an estimated 60% of worldGDP will be digitalised.2 For the FATF, the growth in digital financial transactionsrequires a better understanding of how individuals are being identified and verifiedin the world of digital financial services. Digital identity (ID) technologies are evolvingrapidly, giving rise to a variety of digital ID systems. This Guidance is intended toassist governments, regulated entities3 and other relevant stakeholders indetermining how digital ID systems can be used to conduct certain elements ofcustomer due diligence (CDD) under FATF Recommendation 10.2.An understanding of how digital ID systems work is essential to apply the risk-basedapproach recommended in this Guidance. Section II of the Guidance brieflysummarises the key features of digital ID systems that are explained in detail inAppendix A.3.Section III summarises the main FATF requirementsReliable, independent digital IDaddressed in this Guidance, including the requirement tosystems with appropriate riskidentify and verify customers’ identities using ‘reliable,independent’ source documents, data or informationmitigation measures in place(Recommendation 10(a)). In the digital ID context, therequirement that digital “source documents, data ormay be standard risk, and mayinformation” must be “reliable, independent” means that theeven be lower riskdigital ID system used to conduct CDD relies upon technology,adequate governance, processes and procedures that provideappropriate levels of confidence that the system producesaccurate results. The Guidance clarifies that non-face-to-face customer-identificationand transactions that rely on reliable, independent digital ID systems withappropriate risk mitigation measures in place, may present a standard level of risk,and may even be lower-risk.4.The risk-based approach recommended by this Guidance relies on a set of opensource, consensus-driven assurance frameworks and technical standards for digitalID systems (referred to as ‘digital ID assurance frameworks and standards’) that havebeen developed in several jurisdictions. The International Organization forStandardization (ISO), together with the International Electrotechnical Commission123Capgemini & BNP Paribas (2018), World Payments Report 2018, accessed online International Data Corporation (IDC), IDC FutureScape: Worldwide IT Industry 2019PredictionsFor the purposes of this Guidance, ‘regulated entities’ refers to financial institutions, virtualasset service providers (VASPs) and, designated non-financial businesses and professions(DNFBPs), as defined under the FATF Standards and to the extent DNFBPs are required toundertake CDD in the circumstances specified in R.22. In June 2019, the FATF revisedRecommendation 15 (New Technologies) and INR 15 to, among other things, imposeRecommendation 10 CDD obligations on VASPs. FATF/OECD 2020

6 GUIDANCE ON DIGITAL IDENTITY(IEC), is standardising these digital ID assurance frameworks and updating a range ofISO/IEC technical standards relating to identity, information technology security andprivacy to develop a comprehensive global standard for digital ID systems. An identityassurance framework sets requirements for different ‘assurance levels’ or ‘levels ofassurance’. Assurance levels measure the level of confidence in the reliability andindependence of a digital ID system and its components. While the assurance levelsdeveloped by various jurisdictions may vary in certain respects, for ease of reference,this Guidance primarily refers to the US National Institute of Standards andTechnology (NIST) digital ID assurance framework and standards (NIST Digital IDGuidelines)4 and the EU’s e-IDAS regulation.5 Jurisdictions should consider theapproach set out in this guidance in line with their domestic digital ID assuranceframeworks and other relevant technical standards.65.Digital ID assurance frameworks and standards and AML/CFT regulations havedifferent origins and intended audiences. This Guidance draws links between digitalID assurance frameworks and standards and the FATF’s CDD requirements. Asillustrated in the table below, key components of digital ID systems are relevant tospecific identification and verification requirements under Recommendation 10(a).Accordingly, the digital ID assurance frameworks and technical standards whichdefine these components and set requirements for each assurance level, provide ahighly useful tool for assessing the reliability and independence of digital ID systemsfor AML/CFT purposes.456The NIST 800-63 Digital Identity Guidelines consists of a suite of documents: NIST SP 80063-3 Digital Identity Guidelines (Overview); NIST SP 800-63A: Digital Identity Guidelines:Enrollment and Identity Proofing; NIST SP 800-63B Digital Identity Guidelines:Authentication and Life Cycle Management; and NIST SP 800-63C, Digital IdentityGuidelines: Federation and Assertions.Regulation (EU) N 910/2014 on electronic identification and trust services for electronictransactions in the internal marketA jurisdiction may not have a digital ID assurance framework or technical standards specificto digital ID systems, but may have other technical standards (e.g., IT information security)standards that are highly relevant. FATF/OECD 2020

GUIDANCE ON DIGITAL IDENTITYCDD requirements (natural persons)Identification / verification – R.10 (a) 7Key components of Digital ID systemsIdentity proofing and enrolment (with binding) – Who are you? Obtain attributes(name, DoB, ID # etc.) and evidence for those attributes; validate and verify IDevidence and resolve it to a unique identity-proofed person.Binding—issue credentials/authenticators linking the person inpossession/control of the credentials to the identity proofed individualAuthentication – Are you the identified/verified individual? Establish that theclaimant has possession and control of the binding credentials. Authenticationapplies to 10(a) if the regulated entity conducts identification/verification byconfirming the potential customer’s possession of pre-existing digital IDcredentials.6.The Guidance explains that (1) authentication is relevant to R.10(a) where theregulated entity opens an account for a customer with pre-existing digital IDcredentials – i.e., not an in-house digital ID solution, and (2) that, in a digital financeand digital ID context, effective authentication of customer identity for authorisingaccount access can support AML/CFT efforts.7.Section V is the crux of the Guidance andprovides guidance for government authorities,regulated entities and other relevant parties onhow to apply a risk-based approach to usingdigital ID systems for customer ndation 10(a) and to support ongoingdue diligence in Recommendation 10(d). Therecommended approach is technology neutral(i.e., it does not prefer any particular types ofdigital ID systems). There are two elements ofthis approach:Apply a risk-based approach to using digital ID forCDD: (1) understand the assurance levels of thedigital ID system and (2) assess whether, given theassurance levels, the ID system is appropriatelyreliable, independent in light of the ML/TF risksa. Understanding of the assurance levels of the digital ID system’s maincomponents (including its technology, architecture and governance) todetermine it is a reliable, independent source of information; andb. Making a broader, risk-based determination of whether, given itsassurance levels, the particular digital ID system provides an appropriate FATF/OECD 2020

8 GUIDANCE ON DIGITAL IDENTITYlevel of reliability and independence in light of the potential ML, TF, fraud,and other illicit financing risks at stake.8.Section V explains how to leverage digital ID assurance frameworks and standards forassessing reliability/independence. It also sets out a decision process for regulatedentities to guide decisions about whether the use of digital ID to meet some elementsof CDD is appropriate under FATF Recommendation 10. Governments and regulatedentities will need to adapt this decision process to the particular circumstances of thejurisdiction and of individual entities. Depending upon the digital ID system(s) andregulatory framework in a particular jurisdiction, governments and regulated entitiesmay have different roles and responsibilities in assessing an identity system’sassurance levels and its appropriateness for CDD, as reflected in the decision-makingflow chart for regulated entities, below.9.This Guidance is non-binding. It clarifies the current FATF Standards, which aretechnology-neutral.Figure 1. Decision process for regulated entities FATF/OECD 2020

GUIDANCE ON DIGITAL IDENTITY 910.Section IV of the Guidance explores some of the benefits of digital ID systems, as wellas the risks they pose. Many risks associated with digital ID systems also exist indocumentary IDs. However, identity proofing and/or authenticating individuals overan open communications network (the Internet) creates risks specific to digital IDsystems – particularly in relation to cyberattacks and potential large-scale identitytheft. On the other hand, digital ID systems that mitigate these risks in accordancewith digital ID assurance frameworks and standards hold great promise forstrengthening CDD and AML/CFT controls, increasing financial inclusion, improvingcustomer experience, and reducing costs for regulated entities.11.The Guidance highlights a number of ways in which the use of digitalDigital ID systems canID systems for CDD can support financial inclusion. First, digital IDsupport financialsystems may enable governments to take a more flexible, nuanced,inclusionand forward-leaning approach in establishing the requiredattributes, identity evidence and processes for proving officialidentity – including for the purposes of conducting customer identification andverification at on-boarding in ways that facilitate financial inclusion objectives.Secondly, the digital ID assurance frameworks and standards themselves providesome flexibility in the process that can be used to identity proof and authenticateindividuals, which can be tailored to meet financial inclusion objectives. Lastly,supervisors and regulated entities, in taking a risk-based approach to CDD cansupport financial inclusion, including via the use of digital ID systems, in line with theapproach in the 2017 FATF supplement on CDD and financial inclusion.Recommendations for government authorities12.Develop clear guidelines or regulations allowing the appropriate, risk-baseduse of reliable, independent digital ID systems by entities regulated forAML/CFT purposes. As a starting point, understand the digital ID systemsavailable in the jurisdiction and how they fit into existing requirements orguidance on customer identification and verification and ongoing duediligence (and associated record keeping and third-party reliancerequirements).13.Assess whether existing regulations and guidance on CDD across all relevantauthorities accommodate digital ID systems, and revise, as appropriate, inlight of the jurisdictional context and the identity ecosystem. For example,authorities should consider clarifying that non-face-to-face on-boardingmay be standard risk, or even low-risk for CDD purposes, when digital IDsystems with appropriate assurance levels are used for remote customeridentification/verification and authentication.14.Adopt principles, performance, and/or outcomes-based criteria whenestablishing the required attributes, evidence and processes for provingofficial identity for the purposes of CDD. Given the rapid evolution of digital FATF/OECD 2020

10 GUIDANCE ON DIGITAL IDENTITYID technology, this will help promote responsible innovation andfuture-proof the regulatory requirements.15.Adopt policies, regulations, and supervision and examination proceduresthat enable regulated entities to develop an effective, integrated “riskbased” approach that leverages data flows, technology architecture andprocesses across all relevant digital ID, AML-CFT, anti-fraud and general riskmanagement activities to strengthen all risk-related functions.16.Develop an integrated multi-stakeholder approach to understandingopportunities and risks relevant to digital ID and developing relevantregulations and guidance to mitigate the risks. Assess and leverage, whereappropriate, existing digital ID assurance frameworks and technicalstandards adopted by the authorities responsible for identity,cybersecurity/data protection, and privacy (including technology, security,governance and resource considerations) for assessing the assurance levelsof digital ID systems for use in CDD. In line with FATF Recommendation 2,co-operate and co-ordinate with relevant authorities to facilitate acomprehensive, coordinated approach to understanding and addressingrisks in, the digital ID ecosystem and to ensure the compatibility ofAML/CFT requirements on digital ID systems with Data Protection andPrivacy rules.17.AML/CFT authorities could consider adopting mechanisms to enhancedialogue and cooperation with relevant private sector stakeholders,including regulated entities and digital ID service providers, to help identifykey identity-related opportunities, risks and mitigation measures.Mechanisms could include a regulatory ‘sandbox’ approach to provide asupervised environment to test how digital ID systems interact withnational AML/CFT laws and regulations. Authorities could also considerdeveloping mechanisms to promote cross-industry collaboration inidentifying and addressing vulnerabilities in existing digital ID systems.18.Consider supporting the development and implementation of reliable,independent digital ID systems by auditing and certifying them againsttransparent digital ID assurance frameworks and technical standards, or byapproving expert bodies to perform these functions. Where authorities donot audit or provide certification for IDSPs themselves, they are encouragedto support assurance testing and certification by appropriate expert bodies7so that trustworthy certification is available in the jurisdiction. Authoritiesare encouraged to support efforts to harmonise digital ID assuranceframeworks and standards to develop a common understanding of whatconstitutes a “reliable, independent” digital ID system.19.Apply appropriate digital ID assurance frameworks and technical standardswhen developing and implementing government-provided digital ID.7These expert certification bodies can provide services for a particular jurisdiction or region,or offer their services internationally. FATF/OECD 2020

GUIDANCE ON DIGITAL IDENTITYAuthorities should be transparent about how the jurisdiction’s digital IDsystem works and its assurance levels.20.Encourage a flexible, risk-based approach to using digital ID systems forCDD that supports financial inclusion. Consider providing guidance on howto use digital ID systems with different assurance levels for identityproofing/enrolment and authentication for tiered CDD.21.Monitor developments in the digital ID space with a view to shareknowledge, best practices, and to establish legal frameworks at both thedomestic and international level that promote responsible innovation andallow for greater flexibility, efficiency and functionality of digital ID systems,both within and across borders.Recommendations for regulated entities22.Understand the basic components of digital ID systems, particularlyidentity proofing and authentication, and how they apply to required CDDelements (see Section II and Appendix A).23.Take an informed risk-based approach to relying on digital ID systems forCDD that includes:a. understanding the digital ID system’s assurance level/s,particularly for identity proofing and authentication, andb. ensuring that the assurance level/s are appropriate for theML/TF risks associated with the customer, product, jurisdiction,geographic reach, etc.24.Consider whether digital ID systems with lower assurance levels may besufficient for simplified due diligence in cases of low ML/TF risk. Forexample, where permitted, adopting a tiered CDD approach that leveragesdigital ID systems with various assurance levels to support financialinclusion.25.If, as a matter of internal policy or practice, non-face-to-face businessrelationships or transactions are always classified as high-risk, considerreviewing and revising those policies to take into account that customeridentification/verification measures that rely on reliable, independentdigital ID systems, with appropriate risk-mitigation measures in place, maybe standard risk, and may even be lower-risk.26.Where relevant, utilise anti-fraud and cyber-security processes to supportdigital identity proofing and/or authentication for AML/CFT efforts(customer identification/verification at on-boarding and ongoing duediligence and transaction monitoring). For example, regulated entitiescould utilise safeguards built into digital ID systems to prevent fraud (i.e., FATF/OECD 2020 11

12 GUIDANCE ON DIGITAL IDENTITYmonitoring authentication events to detect systematic misuse of digital IDsto access accounts, including through lost, compromised, stolen, or solddigital ID credentials/authenticators) to feed into systems to conductongoing due diligence on the business relationship and to monitor, detectand report suspicious transactions to authorities.27.Regulated entities should ensure that they have access to, or have a processfor enabling authorities to obtain, the underlying identity information andevidence or digital information needed for identification and verification ofindividuals. Regulated entities are encouraged to engage with regulatorsand policy makers, as well as digital ID service providers, to explore howthis can be efficiently and effectively accomplished in a digital IDenvironment.Recommendations for digital ID service providers828.Understand the AML/CFT requirements for CDD (particularly customeridentification/verification and ongoing due diligence) and other relatedregulations, including requirements for regulated entities to keep CDDrecords.29.Seek assurance testing and certification by the government or anapproved expert body, or where these are not available, anotherinternationally reputable expert body. Where available, participate inpublic sector regulatory ‘sandboxes’ (or other relevant mechanisms) toassess the digital ID system’s assurance levels.30.Provide transparent information to AML/CFT regulated entities about thedigital ID system’s assurance levels for identity proofing, authentication,and, where applicable, federation/interoperability.8While the FATF Standards are only applicable to regulated entities (i.e. financial institutions,virtual asset service providers and designated non-financial businesses and professions),this Guidance is relevant background for digital ID service providers who provide service toregulated entities (for FATF purposes). Ultimately, the regulated entity is responsible for themeeting the FATF requirements. FATF/OECD 2020

GUIDANCE ON DIGITAL IDENTITY 13SECTION I: INTRODUCTION31.The Financial Action Task Force (FATF) is committed to ensuring that the globalanti-money laundering/counter financing of terrorism (AML/CFT) standardsencourage responsible financial innovation. In this regard, the FATF stronglysupports the use of new technologies in the financial sector that align with, andstrengthen, the implementation of AML/CFT standards and financial inclusion goals.932.The rapid pace of innovation in the digital identity (ID) space has reached an inflectionpoint. Digital ID standards, technology and processes, have evolved to a point wheredigital ID systems are, or could soon be, available at scale.Some of these relevant technologies include: a range ofThe rapid pace of innovation hasbiometric technology; the near-ubiquity of the Internet andreached an inflection point.mobile phones (including the rapid evolution and uptake ofDigital ID systems are, or could“smart phones” with cameras, microphones and other“smart phone” technology); digital device identifiers andsoon be, available at scale.related information (e.g., MAC and IP addresses;10 mobilephone numbers, SIM cards, global position system (GPS)geolocation); high-definition scanners (for scanning ID cards, drivers licenses andother documents); high-resolution video transmission (allowing for remoteidentification and verification and proof of “liveness”); artificial intelligence/machinelearning (e.g., for determining validity of government-issued ID); and distributedledger technology (DLT).Potential benefits33.Digital ID systems that meet high technology, organisational and governancestandards hold great promise for improving the trustworthiness, security, privacyand convenience of identifying natural persons in a wide variety of settings, such asfinancial services, health, and e-government in the global economy of the digital age.These digital IDs are referred to as those with higher assurance levels.34.In relation to the FATF Standards, appropriately reliable, independent digital IDsystems could:910 facilitate customer identification and verification at on-boardingsupport ongoing due diligence and scrutiny of transactions throughout thecourse of the business relationship, facilitate other customer due diligence (CDD) measures, andaid transaction monitoring for the purposes of detecting and reportingsuspicious transactions, as well as, general risk management and anti-fraudefforts.See the FATF’s position on FinTech and RegTech (November 3, 2017), available at s/fatf-position-fintech-regtech.html.MAC addresses identify devices, IP addresses identify connections. FATF/OECD 2020

14 GUIDANCE ON DIGITAL IDENTITY35.They also have the potential to reduce costs and increase efficiencies for regulatedentities, and allow for the re-allocation of resources to other AML/CFT functions.36.Reliable, independent11 digital ID systems can also contribute to financial inclusion byenabling unserved and underserved people to prove official identity in a wide rangeof circumstances, including remotely, in order to obtain regulated financial services.Bringing more people into the regulated financial sector further reinforces AML/CFTsafeguards.Potential risks37.Digital ID systems also pose ML/TF risks that must be understood and mitigated.Regulated entities that fail to do so, will also fail to meet the requirements set out inRecommendation 10(a) and requirements under the FATF standards that requireregulated entities to identify, assess and mitigate the money laundering or terroristfinancing risks that may arise in relation to the use of new or developing technologiesfor both new and pre-existing products.1238.These risks are covered in detail in Section IV. Large scale digital ID systems that donot meet appropriate assurance levels pose cybersecurity risks, including allowingcyberattacks aimed at disabling broad swaths of the financial sector, or at disablingthe digital ID systems themselves. They also pose major privacy, fraud or otherrelated financial crimes risks, because cybersecurity flaws can result in massiveidentity theft, compromising individuals’ personally identifiable information (PII).13Risks related to governance, data security and privacy also have an impact onAML/CFT measures. These risks vary in relation to the components of the digital IDsystem but can be more devastating than breaches associated with traditional IDsystems due to the potential scale of the attacks. Advances in technology and welldesigned identity proofing and authentication processes can help mitigate these risksas set out in Section IV and discussed further in Section V.39.Recognising the potential risks and benefits of digital ID systems, the FATF hasdeveloped this Guidance to clarify how digital ID systems can be used to comply withspecific AML/CFT requirements under its standards.Purpose and Target Audience40.111213This Guidance aims to help government agencies develop a clearer understanding ofhow digital ID systems work and to clarify how they can be used under the globalAML/CFT standards. This includes policymakers, regulators, supervisors andexaminers of regulated entities; privacy, data protection and cybersecurityauthorities (as relevant); as well as, oth

63-3 Digital Identity Guidelines (Overview); NIST SP 800-63A: Digital Identity Guidelines: Enrollment and Identity Proofing; NIST SP 800-63B Digital Identity Guidelines: Authentication and Life Cycle Ma

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