Additional customer controls

Understand when more information and checks are relevant.

Some customers and situations call for more than the standard checks, and a few call for less. This topic explains enhanced and simplified due diligence, the triggers that lead to each, and the extra information they involve, such as source of funds and source of wealth.

The remaining guides deal with the checks that sit alongside due diligence: politically exposed persons, targeted financial sanctions, adverse media, and how to assess a screening match. Two closing guides cover timing, when a check can be delayed and what to do when it cannot be completed.

• Enhanced customer due diligence

  Select additional measures that address the customer's actual risk and legal triggers.

• Simplified customer due diligence

  Simplified CDD applies reduced measures only where the legal conditions for it are met and recorded.

• Politically exposed persons and customer checks

  Identify PEP type, the person's role in the service and the applicable conditions.

• Source of funds: trace the transaction's money

  Source of funds establishes how the money for a particular transaction was obtained and where it came from.

• Source of wealth: understand how wealth accumulated

  Source of wealth explains the broader origin of a person's total wealth and assets, not the money in one transaction.

• Targeted financial sanctions in customer checks

  Identify relevant persons and route possible matches for a controlled decision.

• CDD reliance and outsourced identity checks

  Using a supplier differs from relying on another regulated entity's CDD.

• Adverse media and customer risk

  Adverse media can give relevant risk information. Its source, date, accuracy and connection to the customer need examination.

• Screening matches and false positives

  A screening alert is a possible match. Compare the available identity evidence before you decide whether it concerns the customer.

• When can customer due diligence be delayed?

  Delayed CDD has specific legal conditions. A deadline is an outer limit, not a general period in which a business can leave checks incomplete.

• When customer due diligence cannot be completed

  Missing CDD information affects service decisions. Examine the applicable restriction, any legal exception and the separate reporting test.

• What is a special interest person in AML screening?

  A special interest person is a screening product label, not a legal category. Examine the record, identity evidence and source before responding.