Individual Customer Due Diligence

About this course

A verification pass is not a completed customer due diligence file. That single idea is the reason this course exists, and it is the one most often missed by an analyst working quickly through a queue with a system that shows a green tick. Five modules. The first sets the framework: what customer due diligence is for, what initial CDD must establish, what the reformed reasonable grounds standard requires, the four types of CDD and when each applies, and the three quite different questions an online identity process has to answer. The second covers collection in detail, including customer-entered data against extracted data, dropdown fields that produce meaningless purpose statements, and the discipline of not silently overwriting what the customer told you. The third covers verification: documentary and electronic methods, what a data match establishes and what it does not, document authenticity, selfie matching, liveness and biometrics, stolen genuine documents, impersonation, and what to do when verification fails for a legitimate reason. The last two modules are the judgement. The fourth works through discrepancy management as a discipline: the sequence from identifying a difference to documenting a resolution, the difference between a poor image and an altered document, physical and digital manipulation indicators, extraction errors, the five categories of discrepancy an analyst meets daily, conflicting verification results, potential impersonation, when to escalate, and why an analyst records observations rather than conclusions about criminal conduct. The fifth brings it together: nature and purpose in practice, risk-based CDD, the difference between an identity issue and a customer-risk issue, screening, persons acting on behalf, delayed initial CDD, the outcomes available including inability to complete, and how to record reasoning rather than only an outcome. The course assumes no prior AML/CTF study and works at a professional level of depth throughout. It is written for the analyst doing individual onboarding, and for anyone who reviews that work.

Curriculum