CDD/EDD Due Diligence Framework
Conduct defensible CDD/EDD investigations with risk stratification and FinCEN-aligned documentation
What You Can Do
You can conduct structured Customer Due Diligence and Enhanced Due Diligence investigations that meet FinCEN requirements and withstand regulatory examination. The framework guides you through risk stratification, information gathering, beneficial ownership verification, and creates documented decision paths that demonstrate compliance across all customer types—individuals, businesses, trusts, and legal entities.
Features
automatically categorize customers into baseline CDD, standard monitoring, or EDD triggers based on jurisdiction, entity type, and business profile
systematically identify and verify ownership structures exceeding 25% thresholds with multi-source documentation
structured process for identifying and investigating Politically Exposed Persons with required relationship mapping
periodic review cycles with documented risk re-assessment and information updates for existing customers
structured framework for gathering facts, assessing patterns, and documenting suspicious activity referral decisions with defensible reasoning
generates audit-ready file summaries with decision trails, source verification records, and compliance checkpoints
tailored questioning and verification pathways for sole proprietorships, partnerships, corporations, trusts, and non-US legal entities
systematic approach to handling customer information requests with verification requirements and documentation standards
Example Output
Example 1: New Business Customer Risk Assessment
- Customer Type: Limited Liability Company
- Primary Industry: Import/Export (elevated risk sector)
- Risk Level: Standard CDD with EDD indicators
- Required Actions: Verify articles of organization, identify beneficial owners >25%, screen principals against OFAC/PEP lists, obtain business purpose documentation
- Documentation: Ownership verification matrix, source documents checklist, risk decision memo
Example 2: PEP Investigation Output
- Customer: Designated government official (former)
- Finding: PEP status confirmed via public records
- Relationship: Immediate family member identified as account beneficiary
- EDD Trigger: Immediate family of PEP = escalated monitoring required
- Actions: Enhanced source of funds verification, transaction pattern monitoring, quarterly review schedule
Example 3: Beneficial Ownership Clarification
- Structure: Multi-tiered LLC with foreign parent
- Initial Findings: Ownership chain unclear across three entities
- Resolution: Obtained certified cap tables, ultimate beneficial owner identified as non-US citizen
- Compliance Decision: Enhanced due diligence required; foreign ownership documentation filed per FinCEN guidance
What's Included
- SKILL.md instruction file with complete CDD/EDD methodology:
- CDD Risk Stratification Matrix: customer categorization tool with trigger indicators
- Beneficial Ownership Verification Checklist: multi-source documentation requirements and sign-off protocols
- PEP Screening & Relationship Mapping Template: systematic identification workflow with escalation paths
- SAR Decision Framework: structured fact-gathering and reasoning documentation for suspicious activity referrals
- CIU Response Protocol: verification requirements and file update procedures
- Regulatory Examination File Checklist: compliance verification points and documentation standards
Who It's For
- BSA/AML Officers — primary users conducting customer onboarding and periodic compliance reviews
- Compliance Managers — overseeing CDD/EDD quality, training, and examination readiness
- Bank Secrecy Act Program Administrators — implementing institution-wide CDD policies and risk procedures
- Internal Auditors — evaluating compliance file documentation and control effectiveness
- Regulatory Examination Teams — preparing defensible CDD records for FinCEN and OCC reviews
Best For
- New customer account onboarding across all entity types
- Beneficial ownership verification and certification workflows
- Risk-triggered Enhanced Due Diligence investigations
- Periodic customer information refresh and re-assessment
- Suspicious Activity Report decision documentation
- Regulatory examination file preparation and audit trails
- PEP identification and ongoing monitoring protocols
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