EDD (Enhanced Due Diligence)
More intensive customer due diligence applied to higher-risk customers, including PEPs and high-risk jurisdictions.
Enhanced Due Diligence (EDD) is the heightened level of customer due diligence applied to customer relationships that present elevated money laundering, terrorist financing, or sanctions risk. EDD goes beyond standard CDD by gathering more extensive information, requiring senior management approval, increasing monitoring intensity, and reviewing the customer's transaction profile with greater scrutiny.
Triggering factors for EDD include: customers who are Politically Exposed Persons (PEPs—current or former senior government officials and their family members and close associates); customers located in or connected to high-risk jurisdictions (FATF grey/black list countries, countries with significant corruption); customers in higher-risk business sectors (money services businesses, casinos, arms dealers, cryptocurrency exchanges, cash-intensive businesses); customers with complex or opaque ownership structures; customers where the source of funds is unclear or potentially high-risk; and correspondent banking relationships.
EDD measures typically include: additional documentation on source of wealth (where did the customer's assets originate?) and source of funds (where do the specific transaction proceeds come from?); more extensive beneficial ownership verification; senior management sign-off on relationship acceptance and annual review; more frequent transaction monitoring and review; regular communication with the customer to maintain understanding of their business; and geographic restrictions or enhanced scrutiny on transactions involving high-risk countries.
For PEPs specifically, global standards require understanding their government role, assessing the corruption risk of that role, verifying source of wealth, and obtaining senior management approval for both initiating and continuing the relationship. Ex-PEPs who have left government positions remain subject to EDD for a risk-based period (typically 12–24 months minimum).
FAQs
Who qualifies as a Politically Exposed Person (PEP) for EDD purposes?
FATF defines Politically Exposed Persons as individuals who are or have been entrusted with prominent public functions. This includes: heads of state and government, ministers and senior officials, senior judicial officers, senior military officials, senior executives of state-owned enterprises, senior officials of political parties, and senior officials of international organizations. EDD also extends to PEP family members (spouse, children, parents) and close associates (business partners, individuals known to be close associates). The definition varies by jurisdiction—domestic PEPs (officials of the institution's own country) receive EDD under FATF standards but some jurisdictions treat them as standard risk for minor positions.
How should financial institutions handle a customer who becomes a PEP after onboarding?
If an existing customer becomes a PEP (e.g., is appointed to a government position), the institution must escalate the relationship to EDD status. This requires: notifying the institution's compliance function upon identifying the change; collecting additional EDD documentation (PEP questionnaire, source of wealth/funds, business relationship documentation); obtaining senior management approval to continue the relationship; enhancing transaction monitoring parameters; and updating the customer's risk rating. Institutions should maintain screening systems that flag PEP status changes and have clear escalation procedures when a standard-risk customer is identified as a current or former PEP.
What is the source of wealth versus source of funds distinction in EDD?
Source of wealth (SoW) refers to the origin of a customer's entire asset base—how did they accumulate their overall wealth? Common sources include business ownership, inherited assets, investment returns, professional career, or real estate. Source of funds (SoF) refers specifically to the origin of the particular funds being used in a transaction or deposited into an account. A PEP might have clean source of wealth (inherited family business) but source of funds for a specific large deposit requiring separate verification. EDD programs typically require documentation and verification for both—SoW establishes the legitimacy of the customer's wealth overall; SoF verifies each specific transaction's funds provenance.
Related Terms
CDD (Customer Due Diligence)
Process of verifying customer identity and assessing risk before and during a financial relationship.
Beneficial Ownership
Identification of natural persons who ultimately own or control a legal entity above a defined ownership threshold.
Sanctions Screening
Process of checking customers, counterparties, and transactions against government sanctions lists to prevent prohibited activity.
FATF Guidelines
International standards from the Financial Action Task Force setting AML and counter-terrorism financing requirements.
