Customer Due Diligence Checklist UK
Certivus AML team8 minUpdated 2026-06-27
In brief: A UK CDD checklist helps practice teams collect consistent identity, ownership, risk, screening, and evidence records before accepting or continuing a client.
Key points
- Start with the client type: individual, company, trust, partnership, or charity.
- Add ownership and control checks for non-individual clients.
- Finish with a risk decision and next-review trigger.
CDD checklist
Use this checklist as a practical file review:
- Confirm the client type and service.
- Verify the individual, business, trust, or partnership.
- Identify beneficial owners and controllers.
- Understand the purpose of the relationship.
- Record expected activity or transaction context.
- Run PEP, sanctions, and adverse media screening where required by the firm's process.
- Rate the client and matter risk.
- Apply simplified, standard, or enhanced due diligence.
- Record the decision and review date.
- Keep evidence in a way another reviewer can follow.
The missing step in weak files
Weak files often contain documents but not judgement. Add a short decision note: what was reviewed, what risk was found, what was accepted, and when the file should be revisited.
This guide is general information, not legal advice. Check MLR 2017 Regulation 28, GOV.UK's money laundering supervision responsibilities, HMRC's CDD testing guidance, and your supervisor's current sector guidance before making a compliance decision.