Enhanced Customer Due Diligence
What enhanced customer due diligence is and when it is required, how to choose measures proportionate to the risk, how to judge whether the evidence answers the question, and how to run an ECDD investigation through to a reasoned outcome, escalation and the ongoing controls a retained relationship needs.
5 modules · 59 lessons · 323 min
$99
12 months’ access from purchase · ex GST
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- Branded completion certificate
- Knowledge assessment
General information only, current as at 1 September 2026. Not legal, financial or regulatory advice. Laws and AUSTRAC guidance change. Use at your own discretion. See our content disclaimer.
About this course
Enhanced customer due diligence is not standard due diligence done twice. It is a different question, asked because something about the customer or the transaction means the ordinary evidence is no longer enough. This course covers that question end to end: recognising when it arises, answering it properly, and closing it with a decision that holds up. Five modules. The first two establish the ground: what ECDD is and how it differs from initial and ongoing due diligence, then every circumstance that triggers it, including high ML/TF risk, politically exposed persons, targeted financial sanctions, high-risk jurisdictions, and a suspicion that triggers ECDD regardless of the customer’s rating. The third covers selecting measures proportionate to the specific risk rather than applying a standard bundle, source of funds against source of wealth, independent verification, and how to tell evidence that resolves a concern from evidence that merely documents it. The last two are the investigation and its outcome: the investigation method worked as a sequence rather than a checklist, then what a reasoned conclusion looks like on the file, when to escalate, what to do when ECDD cannot resolve the risk it was applied to, whether exit is the answer and when it is not, and the ongoing controls a retained higher-risk relationship needs afterwards. The course assumes working familiarity with customer due diligence rather than legal training, and concentrates on the judgements a practitioner actually has to make.
Curriculum
Understanding Enhanced Customer Due Diligence
- What Enhanced Customer Due Diligence IsPreview6 min
- Why ECDD Matters5 min
- ECDD Applies to All Reporting Entities4 min
- Where ECDD Sits in the Customer Lifecycle5 min
- Standard CDD Compared With ECDD4 min
- Trigger, Measure, Finding and Outcome7 min
- ECDD Is Not a Universal Checklist5 min
- ECDD, Suspicious Matter Reporting and Sanctions Compliance5 min
- Roles, Responsibilities and Getting ECDD Right7 min
When Enhanced Customer Due Diligence Is Required
- Understanding ECDD Triggers3 min
- Mandatory ECDD Circumstances13 min
- The Customer Is Assessed as High Risk7 min
- High Risk Identified During Initial CDD3 min
- Risk Becomes High During an Existing Relationship4 min
- Unusual, Large or Complex Transactions and Arrangements8 min
- Politically Exposed Persons4 min
- High-Risk Jurisdictions4 min
- Nested Services Relationships3 min
- SMR-Related ECDD4 min
- Sanctions Matches and Sanctions-Related Triggers10 min
- Adverse Media and Customer Behaviour as a Trigger4 min
- Practical Trigger-Assessment Method3 min
- Common Mistakes and Best Practice3 min
Selecting ECDD Measures and Assessing Evidence
- A Risk-Based Approach to ECDD Measures4 min
- Matching the Measure to the Risk6 min
- Collecting Additional KYC Information4 min
- Verifying and Re-Verifying KYC Information | Understanding Ownership and Control6 min
- Example: Company Controlled Through Another Entity | Understanding the Nature and Purpose of the Relationship5 min
- Source of Funds | Example: Property Sale6 min
- Source of Wealth5 min
- Third-Party Funding and Connected Parties | Example: Third-Party Property Funding3 min
- Reviewing Transactions, Services and Behaviour6 min
- Measures for a Potential Sanctions Match and Obtaining Information from the Customer6 min
- Assessing the Quality of Evidence5 min
- Practical Example, Selecting Appropriate ECDD Measures9 min
Conducting an ECDD Investigation
- The Purpose and Method of an ECDD Investigation4 min
- Step 1, Understand the Trigger, and Opening Step 25 min
- Step 2 in Detail, the Customer Profile7 min
- Closing the Profile Review, and Step 3, Naming the Gaps6 min
- A Practical Example and Step 4, Define the Investigation Scope5 min
- Step 5, Select the Measures, and Step 6, Review the Activity6 min
- Comparing Activity, Finding Patterns, and Sector-Specific Examples7 min
- Step 7, Screening and Open-Source Research, and Step 8, Requesting Explanations6 min
- Avoiding Tipping Off and Weighing the Customer's Response5 min
- Investigating a Sanctions Match4 min
- Assessing All Findings and Residual Risk4 min
- Documenting the Conclusion and Recommendation5 min
- Comprehensive Practical Case Study11 min
- Common Mistakes and Best Practice3 min
ECDD Outcomes, Escalation and Ongoing Controls
- Reaching an ECDD Outcome. Possible ECDD Outcomes.6 min
- Satisfactory and Unsatisfactory ECDD Outcomes4 min
- Inherent Risk, Controls and Residual Risk5 min
- Updating the Customer-Risk Rating and Senior-Management Approval8 min
- Ongoing Controls After ECDD4 min
- ECDD and SMR Escalation5 min
- Sanctions Outcomes and Escalation5 min
- Declining a Service, Recordkeeping and Quality Assurance8 min
- Practical Case Study, ECDD Outcome and Controls5 min
- An Unsatisfactory Outcome, Common Mistakes and Best Practice6 min