Enhanced Due Diligence Examples for UK Firms
Certivus AML team8 minUpdated 2026-06-27
In brief: Enhanced due diligence examples help staff recognise when a normal CDD file needs stronger evidence, approval, or ongoing monitoring.
Key points
- EDD examples are risk prompts, not automatic decisions.
- PEP exposure, complex ownership, high-risk geography, unexplained funds, and relevant adverse media often justify more work.
- The final decision should be documented in plain language.
Enhanced due diligence examples
Here are common situations where a UK professional firm may need to consider enhanced due diligence:
| Situation | Why it matters | Possible EDD response |
|---|---|---|
| PEP or close associate | Bribery and corruption exposure may be higher. | Senior approval, source-of-wealth context, closer monitoring. |
| Complex ownership | Control may be hidden behind layers or nominees. | Ownership map, extra company records, explanation of control. |
| High-risk jurisdiction | Country risk may affect AML exposure. | Country-risk note and stronger evidence for funds or activity. |
| Unusual source of funds | The funds do not fit the client's profile. | Bank records, contract trail, sale documents, or accountant confirmation where appropriate. |
| Relevant adverse media | Allegations may affect client risk. | Relevance review, client explanation, escalation if unresolved. |
Staff guidance
Ask: "What fact makes this higher risk, what extra evidence would help, and who needs to approve the decision?"
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.