CDD stands for Customer Due Diligence. It is a process that financial institutions and certain businesses use to verify the identity of their customers and assess their risk profile in order to prevent money laundering, fraud, and other financial crimes.
What are the objectives of customer due diligence?
The main objectives of CDD are:
- Identity verification: This involves confirming the identity of a customer through reliable and independent sources, which may include official identification documents like passports, driving licences, and utility bills.
- Understanding customer activity: This entails gaining a clear understanding of the nature and purpose of a customer’s business relationship with the institution. It helps in determining whether the customer’s transactions are consistent with their business profile.
- Assessing risk: CDD helps in evaluating the risk associated with a customer. This involves determining whether a customer is considered low, medium, or high risk based on factors like their industry, location, transaction patterns, and other relevant information.
- Ongoing monitoring: It’s not a one-time process. CDD is an ongoing effort to keep customer information up-to-date and to monitor for any unusual or suspicious activities.
- Compliance with regulatory requirements: Financial institutions and businesses are often required by law to perform CDD as part of anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.
- Risk mitigation: By understanding their customers and their associated risks, institutions can implement appropriate risk mitigation measures. This might include enhanced monitoring, additional documentation, or even terminating a business relationship in extreme cases.
CDD is an integral part of a broader framework known as Know Your Customer (KYC), which also includes procedures for customer acceptance policies, risk management, and ongoing monitoring.
When should we conduct CDD?
The frequency of customer due diligence for a client depends on various factors, including the type of business you’re involved in, the jurisdiction you operate in, and the specific regulatory requirements that apply to your industry.
In general, customer due diligence is an ongoing process. It involves the collection and verification of customer information to ensure that you have a clear understanding of who your customers are, their activities, and their risk profiles. Here are some guidelines to consider:
Risk-based approach: Most jurisdictions advocate for a risk-based approach to CDD. This means that higher-risk clients, such as those involved in complex financial transactions or in industries prone to money laundering or terrorist financing, may require more frequent and thorough CDD.
Regular monitoring: It’s common to conduct periodic reviews of customer information, especially for higher-risk clients. This could range from annual reviews to more frequent checks, depending on the risk assessment.
Trigger events: Certain events can trigger the need for additional due diligence. These events might include significant changes in a client’s business activities, ownership structure, or jurisdiction of operation.
Regulatory requirements: Different jurisdictions have different regulatory requirements. Familiarise yourself with the specific regulations that apply to your industry and location.
Technology and automation: Depending on the scale of your operations, you might use technology and automated solutions to help monitor and update customer information more efficiently.
Adverse media screening: Regularly monitor news sources for any adverse information about your clients. This can be an important aspect of ongoing due diligence.
Client-requested updates: Some clients may proactively provide updated information. This should be integrated into your ongoing CDD process.
Document retention: Ensure you have proper document retention policies in place. This is important for both regulatory compliance and for your own records.
Training and awareness: Ensure your team is well-trained and aware of the importance of ongoing due diligence. They should understand when and how to conduct reviews.
Legal and compliance advice: Consult with legal and compliance experts to ensure that your CDD processes align with current regulations and best practices.
Remember, these are general guidelines, and the specifics may vary based on your industry, location, and the nature of your business. It is important to consult with legal and compliance experts who are knowledgeable about the regulations that apply to your specific situation.
