Enhanced Due Diligence and Escalations

Summary

This guide provides an overview of managing high-risk clients using the Escalations and Enhanced Client Due Diligence (ECDD) features within the AML client onboarding tool.

When to Use This

Use this guide when you encounter a client who has been flagged as high risk or appears suspicious during the onboarding process and requires further investigation or Compliance Officer review.Enhanced Client Due Diligence (ECDD) is typically required when specific high-risk triggers occur, such as dealing with a high-risk Politically Exposed Person (PEP), suspicious activity, or a high-risk country.

Step-by-Step Instructions

1. Identify if the client has been flagged as high risk during the individual risk assessment.
2. Determine if the client requires Enhanced Client Due Diligence, such as a Verification of Funds check.
3. If the client is deemed suspicious by client-facing staff, utilise the Escalations feature to alert the Compliance Officer.
4. Allow the Compliance Officer to review the provided documentation and determine a risk-based approach to proceed.

Common Questions

How is a client identified as high risk? A client may be identified as high risk based on factors such as large physical currency transactions, a high-risk Politically Exposed Person (PEP) (including beneficial owners), suspicious activity, or exposure to a high-risk country, which are flagged by the system's risk assessment tools.

Troubleshooting Tips

If the risk level is not accurately reflected, ensure that all transaction details, such as the amount and type of currency, are entered correctly into the client's profile.