Enhanced due diligence checklist: when standard checks are not enough

An enhanced due diligence checklist is what you reach for when the standard onboarding pack is not proportionate to the risk in front of you. It is not a longer version of the same form: enhanced due diligence asks different questions, demands independent corroboration rather than customer assertion, and sets a review date instead of filing the case away. Firms that skip the checklist tend to apply enhanced checks inconsistently, which is worse than not applying them, because the gaps look like judgement calls nobody can explain.

What triggers enhanced due diligence

Write the triggers down before any individual case, so the decision is not argued case by case.

• A politically exposed person, their family or a known close associate.
• A customer, owner or counterparty connected to a higher-risk jurisdiction.
• Ownership that runs through several layers, nominee arrangements or bearer instruments.
• A relationship conducted entirely remotely with no reliable identity verification.
• Transactions that do not match the stated business model, in size, frequency or direction.
• Anything that has previously produced a suspicious activity report on the same relationship.

Building the enhanced due diligence checklist

Each line should name the evidence, its acceptable sources and who signs it off. Vague lines such as "verify source of wealth" produce vague files.

1. Establish beneficial ownership to a named individual, with registry extracts rather than a customer-drawn diagram.
2. Corroborate source of wealth independently — audited accounts, a sale contract, a tax filing — not a written statement alone.
3. Corroborate source of funds for the specific transaction, which is a different question from source of wealth.
4. Record adverse media and sanctions screening results with the date and the search terms used, so a later reviewer can reproduce them.
5. Obtain senior management approval before the relationship starts, recorded as a decision with a name against it.
6. Set the review date at onboarding — twelve months at most for the highest tier — and diarise it rather than trusting memory.

Enhanced does not mean endless. A checklist without a stopping rule turns into an open case that nobody closes, and an examiner reads a permanently open file as an unresolved risk. Define what "sufficient" looks like for each line and let the reviewer sign it off.

Keeping it consistent across the book

• One version of the checklist, dated, with old versions retained so you can show what the rule was at the time.
• The same fields for every enhanced case, so the population can be counted and sampled.
• Evidence stored against the customer record, not attached to an email thread.
• A visible link back to the standard client due diligence file, because enhanced checks supplement it rather than replace it.
• The same discipline extended to vendors — supplier onboarding raises the same beneficial-ownership questions and is far more often skipped.

Where the evidence lives

Ettex Records keeps each relationship as a structured record with the checklist fields on it, so an enhanced case is a filter rather than a folder someone has to remember to open, and the review date is a field you can sort by. Ettex does not screen names against sanctions or PEP data — that is a data vendor’s job, and you should keep using one. What sits here is the checklist, the evidence you gathered, who approved it and when it is next due.