Enhanced Due Diligence (EDD) Triggers
1. Purpose
This policy (Ref: COMP-AML-004) identifies the triggers that require the application of Enhanced Due Diligence (EDD) and specifies the additional measures that must be applied. EDD is mandated under AMLD6 and FATF Recommendation 10 wherever a higher risk of money laundering or terrorist financing has been identified.
2. Mandatory EDD Triggers
The following situations require the mandatory application of EDD. This list is non-exhaustive; relationship managers and the AML Unit must exercise professional judgement to identify additional scenarios warranting enhanced measures.
2.1 Customer-Related Triggers
- Politically Exposed Persons (PEPs) — All PEPs, their family members, and known close associates. Refer to COMP-KYC-005 for PEP screening requirements.
- High-net-worth individuals — Customers with assets under management or aggregate balances exceeding EUR 1,000,000.
- Complex ownership structures — Entities with multi-layered ownership, nominee shareholders, bearer shares, or trusts where the UBO is not readily identifiable.
- Non-resident customers — Customers domiciled in a jurisdiction different from the booking location of the account.
- Cash-intensive businesses — Customers operating in sectors with inherently high cash usage (e.g., retail, hospitality, currency exchange).
2.2 Geographic Triggers
- Customers, counterparties, or transactions involving FATF high-risk or non-cooperative jurisdictions (refer to the current FATF grey list and black list).
- Jurisdictions identified in the Bank's internal Geographic Risk Assessment as elevated risk.
- Jurisdictions subject to EU or international sanctions programmes.
2.3 Transaction-Related Triggers
- Single transactions or a series of linked transactions exceeding EUR 15,000 where the source of funds is not clearly established.
- Transactions with no apparent economic purpose.
- Correspondent banking relationships.
- Wire transfers exceeding EUR 50,000 to or from high-risk jurisdictions.
2.4 Product and Channel Triggers
- Private banking relationships.
- Trade finance transactions involving high-risk goods or dual-use items.
- Non-face-to-face onboarding without adequate digital identity verification.
3. Enhanced Due Diligence Measures
When EDD is triggered, the following additional measures must be applied in addition to standard CDD:
| EDD Measure | Description |
|---|---|
| Senior Management Approval | The customer relationship must be approved by a senior manager (VP level or above) before onboarding or continuation. |
| Enhanced Source of Funds/Wealth | Obtain and verify detailed evidence of the source of funds and source of wealth (e.g., tax returns, audited accounts, property records). |
| Adverse Media Screening | Conduct enhanced adverse media screening using the Bank's designated screening tool and document findings. |
| Increased Monitoring | Apply heightened transaction monitoring thresholds and review frequency (no less than every 6 months). |
| Site Visit (if applicable) | For corporate clients rated high-risk, a physical or virtual site visit may be required to verify business operations. |
| Independent Verification | Verify customer information through independent, reliable sources beyond those provided by the customer. |
4. Documentation and Record Keeping
All EDD assessments must be documented in the Bank's CDD system, including the rationale for applying EDD, the measures taken, the outcome of senior management review, and any conditions imposed. Records must be retained for a minimum of five (5) years following the end of the business relationship.
5. Escalation
Where EDD reveals information that gives rise to suspicion, the matter must be escalated via the SAR procedure (COMP-AML-002). If EDD requirements cannot be satisfactorily met, the relationship must not be established or must be referred to the AML Unit for potential exit.
6. Review
This policy is reviewed annually by the AML Unit. Next review: Q2 2027.