Strong Customer Authentication (SCA) is a European regulatory requirement aimed at making online payments more secure.
What is Customer Due Diligence?
Customer Due Diligence (CDD) is a process employed by businesses and financial institutions to assess and verify the identity of their customers
Customer Due Diligence (CDD) is a process employed by businesses and financial institutions to assess and verify the identity of their customers, evaluate the potential risks associated with establishing a business relationship, and ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. The primary purpose of CDD is to prevent illicit activities, such as money laundering, terrorist financing, and other financial crimes.
The CDD process typically involves gathering relevant information and documentation from the customer, including but not limited to:
- Identification data: Full name, date of birth, address, nationality, etc.
- Supporting documentation: Government-issued identification (passport, driver's license,
etc.), proof of address, and in some cases, information on the source of funds or wealth.
- Business information: For corporate customers, details about the company's structure, ownership, and legal status are collected.
There are three main levels of Customer Due Diligence:
- Standard CDD: This level applies to most customers and involves verifying their identity using reliable and independent sources of information.
- Simplified CDD: This level is used for customers presenting lower risk, such as those with a well-established relationship or belonging to a low-risk category. The verification process may be less rigorous compared to standard CDD.
- Enhanced CDD: Enhanced due diligence is conducted for higher-risk customers or in specific situations that pose elevated risks. It involves obtaining additional information and scrutinising the customer more closely.
The CDD process is an essential component of a business's overall AML and CTF compliance program. By conducting thorough due diligence, businesses can identify and mitigate potential risks, detect suspicious activities, and protect themselves from legal and reputational consequences related to money laundering and terrorist financing activities.
When is Customer Due Diligence (CDD) required?
Customer Due Diligence (CDD) is typically required in various situations and is mandated by anti-money laundering (AML) and counter-terrorism financing (CTF) regulations in many countries. The specific requirements for CDD may vary depending on the jurisdiction and the type of business or financial institution involved. Here are some common situations when CDD is required:
- Opening a new account: When a customer wants to open a bank account, investment account, or any other financial account, CDD must be conducted to verify the customer's identity and assess potential risks.
- Establishing a business relationship: Before initiating a business relationship with a customer, such as providing financial services or engaging in significant transactions, CDD is required to ensure that the customer's identity and background are legitimate.
- Carrying out occasional transactions above specified thresholds: When a customer conducts one or more transactions that exceed certain monetary thresholds, financial institutions are required to perform enhanced CDD to understand the nature of the transactions and the source of funds.
- Transactions with politically exposed persons (PEPs): If a customer is considered a politically exposed person, meaning they hold a prominent public position or have close associations with such individuals, enhanced due diligence is necessary due to the elevated risk of corruption and money laundering.
- Suspicious activity: If a business or financial institution detects suspicious activities or transactions that may indicate potential money laundering or terrorist financing, it must conduct additional CDD to assess the risk and report it to the relevant authorities if necessary.
- Changes in customer information: When there are significant changes in customer information, such as a change of address or ownership, it may trigger a review and update of the CDD information.
- International transactions and correspondent banking: Cross-border transactions and correspondent banking relationships require enhanced due diligence to ensure compliance with international AML and CTF standards.
It's important to note that the specific CDD requirements may differ based on local laws and regulations, as well as the type of business or institution involved. Businesses and financial institutions are expected to have robust AML and CTF compliance programs in place to ensure they adhere to the relevant CDD requirements and effectively manage associated risks.
Customer Due Diligence for Banks
Customer Due Diligence (CDD) for banks is a critical component of their anti-money laundering (AML) and counter-terrorism financing (CTF) compliance efforts. Banks are subject to stringent regulatory requirements to verify the identity of their customers, assess the potential risks associated with their accounts and transactions, and detect and prevent illicit financial activities. Here are some key aspects of CDD for banks:
- Customer Identification: Banks must obtain and verify the identity of their customers using reliable and independent sources of information. This includes collecting information such as full name, date of birth, residential address, nationality, and government-issued identification documents (e.g., passport, driver's license).
- Beneficial Ownership: Banks are required to identify and verify the beneficial owners of corporate customers. Beneficial owners are individuals who ultimately own or control a legal entity, and banks must take reasonable steps to determine their identities.
- Risk-Based Approach: Banks need to adopt a risk-based approach to CDD, meaning they assess the risk associated with each customer and tailor the level of due diligence accordingly. Higher-risk customers, such as politically exposed persons (PEPs) or customers engaged in certain high-risk industries, require enhanced due diligence.
- Ongoing Monitoring: Banks must continuously monitor customer accounts and transactions for any unusual or suspicious activity. Ongoing monitoring helps to identify potential red flags and trigger additional investigation when necessary.
- Record Keeping: Banks are required to maintain records of the CDD process and any related documentation for a specified period as mandated by local regulations.
- Training and Compliance Programs: Banks need to ensure that their staff is adequately trained in AML and CTF regulations and that robust compliance programs are in place to address the risks effectively.
- Reporting Suspicious Activity: If a bank identifies any suspicious or potentially illegal transactions, it must report such activity to the appropriate authorities, such as financial intelligence units, as per local regulations.
- Correspondent Banking Relationships: Banks engaging in correspondent banking relationships (where one bank provides services on behalf of another) must also conduct due diligence on correspondent banks to manage potential risks associated with money laundering and terrorist financing.
Non-compliance with CDD requirements can lead to severe penalties, including fines and reputational damage. Therefore, banks invest significant resources in ensuring their CDD processes are robust, effective, and aligned with applicable AML and CTF regulations.
How does Customer Due Diligence Work for Know Your Customer (KYC) & Anti Money Laundering (AML) Practices?
Customer Due Diligence (CDD) is an essential part of Know Your Customer (KYC) and Anti-Money Laundering (AML) practices. KYC and AML are regulatory frameworks designed to prevent financial institutions and businesses from being used for money laundering, terrorist financing, and other illicit activities. CDD is a key process within these frameworks and involves several steps to ensure the identification and risk assessment of customers. Here's how CDD works in the context of KYC and AML practices:
- Customer Identification: The first step in CDD is to identify the customer. This involves collecting basic information about the customer, such as their full name, date of birth, address, nationality, and government-issued identification documents (e.g., passport, driver's license).
- Verification of Identity: Once the customer's information is collected, the financial institution or business verifies the customer's identity using reliable and independent sources. This may involve cross-referencing the provided information with official databases or using third-party identity verification services.
- Understanding the Customer's Profile: In addition to identity verification, the financial institution aims to understand the customer's profile and risk characteristics. This may include assessing the customer's occupation, source of income, expected transaction volume, and the purpose of the account or relationship.
- Risk Assessment: Based on the gathered information, the financial institution or business conducts a risk assessment of the customer. The risk assessment involves categorizing the customer as low, medium, or high risk, depending on factors such as their occupation, country of residence, transaction history, and involvement in high-risk industries.
- Enhanced Due Diligence (EDD): If the customer is deemed to be higher risk, the financial institution may perform Enhanced Due Diligence. EDD involves more extensive research and monitoring to gain a deeper understanding of the customer's financial activities and the source of their funds.
- Ongoing Monitoring: CDD is not a one-time process; it involves continuous monitoring of customer accounts and transactions to identify any suspicious or unusual activities. Ongoing monitoring helps detect potential red flags and triggers additional investigation when necessary.
- Record Keeping: Throughout the CDD process, the financial institution maintains records of the customer's information, verification documents, risk assessments, and any actions taken based on the monitoring results. These records are essential for regulatory compliance and may be subject to audits.
- Reporting Suspicious Activity: If the financial institution identifies any suspicious or potentially illegal transactions during the CDD process or ongoing monitoring, it must report such activity to the appropriate authorities, such as financial intelligence units, as required by AML regulations.
By conducting thorough CDD as part of their KYC and AML practices, financial institutions and businesses can effectively identify and mitigate the risks associated with money laundering and other financial crimes, ensuring compliance with regulatory requirements and protecting themselves from potential legal and reputational repercussions.
Learn more about Know Your Customer in our article Why is KYC Important?
How can Businesses get started with Customer Due Diligence?
Getting started with Customer Due Diligence (CDD) is essential for businesses, particularly those operating in regulated industries or dealing with financial transactions. Implementing a robust CDD process helps mitigate risks associated with money laundering, terrorist financing, and other financial crimes, while also ensuring compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. Here are the steps businesses can take to get started with CDD:
- Understand Applicable Regulations: The first step is to familiarise yourself with the AML and CTF regulations that apply to your business. These regulations may vary depending on your industry, country, and the nature of your transactions. Consult legal experts or compliance professionals to ensure you have a clear understanding of your obligations.
- Develop a CDD Policy: Create a comprehensive CDD policy that outlines the processes and procedures your business will follow to identify and verify customers, conduct risk assessments, and monitor ongoing activities. The policy should align with the relevant regulatory requirements and be adaptable to changes in the regulatory landscape.
- Categories Customer Risk: Develop a risk assessment framework that categorises customers into low, medium, and high-risk groups based on factors such as their industry, location, transaction volume, and source of funds. This risk-based approach will help determine the level of due diligence required for each category.
- Collect Customer Information: Implement processes to collect necessary customer information, such as full name, date of birth, address, and government-issued identification documents. For corporate customers, obtain information about the company's ownership structure and legal status.
- Verify Customer Identity: Use reliable and independent sources to verify the identity of your customers. This may involve conducting electronic identity verification, checking government databases, or using third-party identity verification services.
- Enhanced Due Diligence (EDD): For higher-risk customers or situations that warrant additional scrutiny, conduct enhanced due diligence. EDD may involve gathering more detailed information about the customer, their financial activities, and the source of their funds.
- Implement Ongoing Monitoring: Establish procedures for ongoing monitoring of customer accounts and transactions to identify any suspicious activities. This could involve using transaction monitoring software or manual reviews, depending on your resources and transaction volume.
- Train Staff and Build Awareness: Educate your employees about the importance of CDD, AML, and CTF compliance. Ensure that staff members responsible for customer onboarding, compliance, and monitoring are well-trained in the CDD process and understand their roles in mitigating risks.
- Maintain Records: Keep thorough and accurate records of the CDD process, risk assessments, and any actions taken based on monitoring results. Adequate record-keeping is crucial for regulatory compliance and potential audits.
- Review and Update: Periodically review and update your CDD policies and procedures to stay abreast of regulatory changes and industry best practices. Ensure that your CDD program remains effective and aligned with the evolving risk landscape.
By following these steps, businesses can establish a strong foundation for their Customer Due Diligence efforts, reducing the risk of financial crimes, ensuring regulatory compliance, and protecting their reputation in the market. It's important to remember that each business's CDD process may vary based on its specific industry, jurisdiction, and risk profile. Seeking guidance from legal and compliance experts can further assist in tailoring the CDD program to the business's unique needs.