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Enhanced customer due diligence (ECDD) program

Part A of your anti-money laundering and counter-terrorism financing (AML/CTF) program must include an enhanced customer due diligence (ECDD) program that documents the actions you take when the money laundering or terrorism financing risk is high.

You must monitor all customers with a view to identifying, mitigating and managing ML/TF risks. The due diligence measures that are appropriate for a particular customer may change over time as the ML/TF risk profile of the customer changes.

Enhanced customer due diligence involves carrying out extra checks on a customer’s identification, collecting additional information and doing additional verification.

Carrying out ECDD allows you to decide whether a suspicious matter should be reported. ECDD plays an important role in detecting, disrupting and preventing money laundering and terrorism financing. It also protects your business or organisation from being exploited for criminal activity.

Suspicious matter reports and ECDD

Submitting a suspicious matter report (SMR) does not manage the ongoing risk of a customer on its own, nor does it alter the fact that a customer is high risk. When a suspicion is formed (and an SMR submitted) about a customer, you also need to apply ECDD.

When to apply your ECDD

You must apply your ECDD in the following high-risk situations.

Your ECDD program and ECDD measures


Your ECDD program must:

  • define the types of customers, designated services, channels and jurisdictions that you consider to be high or greater level of risk, and ensure procedures allow for consistent implementation of ECDD processes
  • specifically identify who is responsible for carrying out ECDD
  • establish controls for consistently applying ECDD to ensure its operation, monitoring and internal reporting.

The ECDD measures you use must be appropriate to the situation, including a range of the measures outlined below. It is also important to maintain an auditable trail of decision making.

The content on this website is general and is not legal advice. Before you make a decision or take a particular action based on the content on this website, you should check its accuracy, completeness, currency and relevance for your purposes. You may wish to seek independent professional advice.

Last updated: 15 Apr 2021
Page ID: 134

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