The enhanced due diligence process in sequence: the enhanced due diligence procedures each step needs, and where it rejoins the ordinary cdd process

Updated

An enhanced due diligence process is usually written as a longer version of the standard one, which hides the two steps that are genuinely different in kind rather than in degree. This page sets the sequence out, marks those two steps, and says what each one has to produce so the file reads as a decision rather than a folder.

Trigger, then scope

The process starts when the rating escalates, which may be at onboarding or at any review. The first step after the trigger is to scope: decide what this particular customer's enhanced file will contain, because enhanced is not a fixed list and pretending it is produces irrelevant evidence. Scoping takes minutes and it is the step most often skipped, which is why so many enhanced files contain three documents nobody needed and not the one that mattered.

The two steps that differ in kind

First, establishing source of wealth and source of funds, which is narrative work rather than collection. Second, forming and writing down an expectation of the customer's activity, so that anybody looking later has something to compare against. Neither of these has a document that completes it. Both are finished when a competent reader would say the picture is coherent, which is a judgement and has to be signed by a person.

Approval, then back into the ordinary cycle

An approver accepts the file, by name, on a date, with any conditions recorded. After that the customer rejoins the ordinary process on a shorter interval: the reviews are normal reviews, they just come round sooner and they re-ask the two narrative questions rather than only checking that the documents are current. That last point is where enhanced reviews are usually weakest, because re-checking a passport is easy and re-checking a story is not.

Questions people ask about enhanced due diligence process

How long does an enhanced due diligence process take?

Longer than a standard file by a multiple, not a margin, and the time is in the narrative rather than the collection. Measuring your own multiple is worth doing, because it is what makes the review load from a small enhanced population visible.

Do enhanced procedures need to be written separately?

They need to be written. Whether they live in a separate document or a section of the main policy matters less than that they say what scoping means, who approves, and what the interval is.

What ends an enhanced due diligence process?

An approval with a name and a date, and a next review date in the future. Without both of those the process has stopped rather than finished.

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