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AML & KYC

Enhanced Due Diligence (EDD)

An elevated set of due-diligence measures applied when the customer, jurisdiction or transaction is assessed as high-risk under the risk-based approach.

Also known asEnhanced CDD

Definition

Enhanced Due Diligence (EDD) is the deeper level of scrutiny applied to customers, relationships or transactions presenting a higher risk of money laundering or terrorist financing. EDD is mandatory in defined scenarios and otherwise triggered by the institution's own risk-based methodology.

When EDD is mandatory

  • The customer is a Politically Exposed Person, a family member or close associate of a PEP.
  • The customer or transaction involves a high-risk third country listed by the EU Commission or FATF.
  • The relationship involves complex or unusually large transactions with no apparent economic purpose.
  • Correspondent banking with a non-EU institution.
  • Private banking, real-estate transactions above thresholds, and certain crypto exposures.

Additional EDD measures

  1. Obtain additional identification and beneficial-ownership information.
  2. Conduct independent screening against extended lists, including adverse media.
  3. Establish source of funds and source of wealth, with documentary evidence.
  4. Obtain senior management approval before entering or continuing the relationship.
  5. Apply enhanced ongoing monitoring with tighter alert thresholds.

Regulatory anchor

AMLD4 Articles 18–24 in the EU, FATF Recommendation 12 (PEPs) and 19 (high-risk countries). The FCA SYSC 6.3 in the UK, BaFin AuA in Germany, and the ACPR AML guidance in France all expand on EDD expectations.