The enhanced due diligence report and the enhanced due diligence checklist that produces it, and how a customer due diligence checklist differs at the standard level

Updated

A checklist and a report do different jobs and firms often produce only one of them. The checklist makes sure nothing was missed. The report is what somebody reads later to understand the decision. An enhanced file needs both, and the report is the half that gets left out because it cannot be produced by ticking.

What the checklist is for

Completeness, and nothing else. It lists what this customer's level requires, it is completed by the person doing the work, and its output is a set of yes and no answers with dates. Its value is entirely in being specific to the level: one generic checklist applied to every customer produces the same weakness as one evidence set applied to every customer, which is that the standard files are over-collected and the enhanced ones are under-evidenced.

What the report has to contain

A short narrative that a competent stranger could read and follow: who the customer is, what they do, where the wealth and the funds come from, what activity you expect, what the residual concerns are, and why the relationship was accepted on these terms. It is a page, not a dossier. The test is whether somebody who has never met the customer could answer a question about them from it, which is exactly the test that gets applied in practice.

The standard-level version is shorter and still real

A customer due diligence checklist at the standard level is much shorter and still ends in a decision with a reason on it. The failure at this level is different: not an absent narrative but an absent reason, so the file says standard with nothing behind the word. One sentence saying why the ordinary level was appropriate turns a rating into a judgement, and it costs almost nothing at the time.

Questions people ask about enhanced due diligence report

What should an enhanced due diligence report include?

Who the customer is, what they do, source of wealth and source of funds, expected activity, residual concerns, and the basis on which the relationship was accepted, with the approver and the date.

Can the checklist replace the report?

No. A completed checklist proves the steps were done and says nothing about what you concluded. The conclusion is what somebody will ask you for.

Where should the checklist and report live?

On the customer record, with the date each was completed and the person who completed it. Kept anywhere else, they become documents somebody has to find rather than facts about the customer.

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