The integrity and trustworthiness of staff is of great importance to businesses. Trustworthy staff enhance a business's credibility with customers and contributes to the reputational capital of a business. Employee due diligence refers to the processes whereby a business screens its staff members for ML/TF risk. As it is normal business practice to screen potential employees to ensure their suitability for a position within your organisation this can be extended to address AML/CTF issues, for example:

• is there a process to ensure your employees are screened for ML/TF risk before they are employed?
• what happens when an employee is promoted or does a different job within the business?

A reporting entity should consider the potential ML/TF risks associated with prospective employees and apply screening procedures if appropriate. This also applies to assessing the need for re-screening employees who are transferred or promoted. For example, a reporting entity may determine that frontline staff positions present a lower ML/TF risk than positions in a capital markets area or private banking unit, so that the AML/CTF program will identify whether re-screening is required when a staff member is transferred from a lower risk position to a higher risk position.