Compliance

Enhanced Due Diligence EDD

Stands for: Enhanced Due Diligence

A stricter level of customer scrutiny applied to higher-risk relationships, typically including source-of-wealth checks and senior management approval.

Definition

**Enhanced Due Diligence (EDD)** is the heightened tier of customer scrutiny mandated by FATF Recommendation 10 paragraph c and FATF Recommendation 19 on high-risk countries. It applies wherever the institution's risk assessment, the law, or supervisory guidance flags a relationship as higher risk: Politically Exposed Persons, customers from high-risk third countries, complex or non-transparent ownership chains, private banking customers, correspondent banking relationships, and customers in cash-intensive sectors.\n\nThe additional measures, on top of standard CDD, typically include obtaining senior management approval before establishing or continuing the relationship, conducting source-of-wealth and source-of-funds checks (not just the immediate transaction source), gathering additional information on the purpose of the relationship, increasing the frequency and depth of ongoing monitoring, and recording the rationale for accepting the elevated risk.\n\nEDD is not a static checklist. It is a documented, proportionate response to identified risk factors, and the institution must be able to demonstrate why each measure was selected and how it mitigates the assessed risk in supervisory examinations.

When you'll encounter it

You will encounter EDD when onboarding a PEP, when your business is in a higher-risk jurisdiction per the EU high-risk third countries list or FATF grey or black lists, when the ownership structure spans several jurisdictions or includes nominees, and when the expected transaction volume or pattern is unusual for your customer profile.

FAQ

Is EDD always mandatory for PEPs?

Yes. FATF Recommendation 12 and the EU AML Directives require EDD for foreign PEPs as a fixed rule. For domestic PEPs the requirement is risk-based, but most institutions apply EDD by default. PEP status normally extends to family members and known close associates for a defined cooling-off period after the person leaves office.

What is source of wealth versus source of funds?

Source of funds is the immediate origin of the money used in a specific transaction, such as a salary payment, sale proceeds, or loan drawdown. Source of wealth is the broader origin of the customer's total net worth: career earnings, inheritance, business sale, or investment returns over time. EDD asks about both and documents corroborating evidence.

Can EDD be outsourced?

Reliance on third parties is permitted under FATF Recommendation 17, but ultimate responsibility for the EDD outcome remains with the regulated entity. The institution must satisfy itself that the third party meets equivalent standards, and underlying CDD records must be available without delay on request.

References

  1. FATF Recommendation 10 paragraph c, and Recommendation 19 https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html
  2. FATF Guidance on Politically Exposed Persons (Recommendations 12 and 22) https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Pep-r12-r22.html
  3. European Banking Authority Guidelines on ML/TF risk factors https://www.eba.europa.eu/regulation-and-policy/anti-money-laundering-and-countering-financing-terrorism