When is EDD mandatory?
Across most regimes, EDD is mandatory for:
- Foreign PEPs and their RCAs.
- Customers from FATF "high-risk" or "increased monitoring" jurisdictions.
- Cross-border correspondent banking relationships.
- Complex or unusually large transactions with no apparent economic or lawful purpose.
- Any relationship the firm itself rates as high-risk.
In the EU under AMLD5/6, EDD is also mandatory for transactions involving high-value goods dealers, crypto-asset service providers in certain configurations, and shell-bank intermediaries.