Enhanced due diligence is often discussed as an onboarding event, which leaves the longer half of it undescribed. For the customers who warrant it, the enhanced level continues for as long as the relationship does, and the between-reviews part has a name and almost no written procedure in most firms. This page is about both halves, and mostly about the second.
Where it sits in the programme
Enhanced due diligence is a level within KYC, triggered by the risk rating, applied at onboarding and re-applied at every review while the rating stands. Writing it as a separate programme is a common structural mistake: it produces two policies, two owners and two review calendars, and customers escalate between them without anything moving. One programme with levels, one calendar, one owner per customer.
What monitoring means here, and what it does not
For an enhanced relationship, monitoring means keeping the picture current between formal reviews: acting on things you learn, whether from the customer, from public information or from your own operations, and recording what you did about them. It does not mean transaction monitoring, which is a different discipline with a different owner and a different product, and this site does not do it. The distinction matters because a firm that has bought transaction monitoring often believes the ongoing part of enhanced due diligence is covered, and it is not.
Make the trigger land somewhere
The practical failure is that somebody learns something about an enhanced customer and there is nowhere to put it. If the only place is an email to a colleague, then the fact exists in the firm and not on the file, and at the next review nobody will find it. A record that accepts a dated note against the customer, attributable to a person, is a small feature that decides whether ongoing enhanced due diligence exists at all in your firm.
Questions people ask about enhanced due diligence kyc
Is enhanced due diligence monitoring the same as transaction monitoring?
No. Transaction monitoring watches activity and generates alerts, and it is a separate product and discipline. Enhanced monitoring in this sense is keeping the customer picture current between reviews and recording what you learn.
How often should an enhanced relationship be formally reviewed?
On the interval your policy sets for that rating, which should be materially shorter than the standard one. What matters more than the exact figure is that the date is on the record and that missing it is visible.
Who owns an enhanced customer between reviews?
One named person, ideally the same one who will do the review. Ownership in the abstract means nothing arrives anywhere, which is how a firm ends up with an enhanced book nobody is actually watching.