This specialized course focuses on enhanced due diligence requirements and techniques for managing high-risk customer relationships in compliance with global AML/CFT standards. Participants will learn advanced methodologies for identifying high-risk customers, conducting thorough background investigations, and implementing ongoing monitoring controls. The course covers specific high-risk categories including PEPs, correspondent banking relationships, cash-intensive businesses, and non-resident customers. Through practical case studies and interactive exercises, learners will develop the expertise needed to effectively manage high-risk relationships while meeting regulatory expectations.
Enhanced Due Diligence (EDD) for High-Risk Customers
Anti-Money Laundering AML/CFT
October 25, 2025
Introduction
Objectives
Key Learning Objectives:
- Understand EDD regulatory requirements and expectations
- Learn to identify and categorize high-risk customers
- Master source of wealth and source of funds verification
- Develop skills in conducting background investigations
- Learn ongoing monitoring techniques for high-risk relationships
- Understand senior management approval processes
- Master documentation standards for EDD processes
- Learn risk mitigation strategies for high-risk customers
- Develop skills in dealing with complex ownership structures
Target Audience
- AML/CFT compliance officers
- Relationship managers and private bankers
- Risk management professionals
- Customer onboarding specialists
- Wealth management professionals
- Corporate banking staff
- Legal and compliance counsel
- Audit and testing personnel
Methodology
- Case studies of high-risk customer relationships
- Practical EDD investigation exercises
- Source of wealth verification simulations
- Role-playing senior management approvals
- Document analysis and validation practice
- Group discussions on complex scenarios
- Regulatory requirement analysis
Personal Impact
- Enhanced investigative and analytical skills
- Improved understanding of high-risk customer management
- Stronger due diligence documentation abilities
- Better risk assessment and decision-making capabilities
- Increased confidence in dealing with complex relationships
- Career advancement in specialized compliance roles
Organizational Impact
- Reduced high-risk customer compliance exposure
- Enhanced regulatory compliance and examination readiness
- More effective risk management of high-value relationships
- Improved customer risk assessment accuracy
- Stronger governance and oversight framework
- Better resource allocation for high-risk management
Course Outline
Unit 1: EDD Fundamentals and Regulatory Framework
EDD Requirements and Expectations- Regulatory basis for enhanced due diligence
- Risk-based approach application
- Trigger events for EDD application
- Global standards and jurisdictional variations
- Politically Exposed Persons (PEPs)
- Correspondent banking relationships
- Private banking and wealth management
- Non-resident and cross-border customers
Unit 2: PEP Management and Investigation
PEP Identification and Categorization- PEP definition and categories
- Family members and close associates
- Domestic vs foreign PEP distinctions
- Screening tools and database usage
- Background investigation techniques
- Source of wealth verification
- Ongoing transaction monitoring
- Senior management approval requirements
Unit 3: Complex Customer Structures
Legal Entity Investigations- Complex ownership structure analysis
- Trust and foundation due diligence
- Offshore company investigations
- Nominee and intermediary relationships
- Multi-layer ownership mapping
- Control and ownership distinction
- Documentation requirements
- Ongoing verification processes
Unit 4: Source of Wealth and Funds Analysis
Wealth Verification Techniques- Documentary evidence requirements
- Open source intelligence gathering
- Professional advisor verification
- Consistency testing and validation
- Expected vs actual activity analysis
- Behavioral pattern monitoring
- Trigger events and re-assessment
- Enhanced monitoring system parameters
Unit 5: EDD Program Management
Governance and Oversight- EDD program framework development
- Roles and responsibilities definition
- Management reporting and metrics
- Quality assurance and review processes
- Account restrictions and limitations
- Enhanced controls and monitoring
- Relationship exit strategies
- Continuous risk assessment
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