Customer Due Diligence (CDD)

Periodic refresh and updates to keep data accurate.

Formal CDD is required by regulation at account opening.

Basic screening (e.g., PEP, sanctions) can happen before fully onboarding.

During onboarding, thoroughly verify business registration credentials and beneficial ownership details for newly formed corporate entities. Cross-reference public registries, check for nominee directors, and confirm the existence of genuine commercial premises or activities. This proactive measure helps detect shell company characteristics, such as paper-only businesses and suspiciously shared addresses, before the relationship is established.

At onboarding, require complete and verified beneficial ownership details, validating the company’s genuine operational purpose. Cross-check official registries to confirm that addresses, commercial activities, and corporate officers are consistent with a legitimate business model rather than a short-lived or paper-only entity. This foundational scrutiny helps expose newly established shells lacking actual commercial substance.

Implement comprehensive Customer Due Diligence (CDD) measures for corporate structures operating across multiple jurisdictions by collecting and validating official formation documents, beneficial ownership data, and relevant licenses from each jurisdiction involved. This measure directly addresses layering vulnerabilities by mapping out all owners across different regions, preventing undisclosed beneficial interests.

Collect and verify detailed customer information during onboarding, including all authorized depositors and their relationships to the primary account holder. Corroborate stated income or business activities with expected cash deposit levels, and reject or query unsubstantiated large cash inflows.

Obtain and verify official business registrations, beneficial ownership details, and trade references for all entities seeking trade finance. Cross-check the provided information with external databases to confirm that company operations, owners, and stated shipping capabilities align with invoice claims. This helps to detect front or shell entities commonly used for invoice manipulation.

During onboarding and periodic reviews, confirm that the customer’s stated line of business matches the goods or commodities they are shipping internationally. Validate the company’s trading history, identify beneficial owners, and ensure declared transaction volumes and values align with the customer's known profile.

At onboarding, require full disclosure of all controlling parties behind legal entities, including nominee directors and trustees. Cross-check customer-provided documents with official registries and relevant external data sources to confirm the legitimacy of each corporate link. This measure directly addresses asset cloaking by preventing anonymous or opaque relationships from being established in the institution.

Obtain and verify identity information and beneficial ownership for clients purchasing or selling real estate, ensuring that legal entities (e.g., LLCs or trusts) do not obscure ultimate ownership. Confirm the legitimacy of the property’s stated value by reviewing local sales data and independent valuations. Require documented proof of funds (e.g., tax returns, business financials) that match the nature of the transaction before proceeding. This clear verification process helps detect shell companies or front entities attempting to inject illicit money into real estate.

Collect and verify identity and beneficial ownership details from clients engaged in foreign property investments, ensuring they align with official land records and corporate filings. If discrepancies or undisclosed controlling parties arise, escalate to enhanced due diligence procedures or deny the transaction.

Obtain and authenticate key rental information during onboarding, including lease agreements, property ownership records, and tenant details. Cross-check the stated monthly rent against local market benchmarks and ensure that the customer’s financial profile supports any declared rental income streams.

Collect and verify complete identification details for real estate buyers, including beneficial ownership for legal entities, before finalizing all-cash transactions. Document expected funding sources to compare with actual payment patterns and immediately address discrepancies that indicate potential illicit financing.

Collect and verify detailed information on parties involved in real estate purchases and sales, including beneficial owners, declared incomes, and supporting documentation for large deposits. Cross-check the provided data against official property records and external sources to identify frequent or unexplained property flips indicative of layering.

During onboarding and routine account reviews, confirm each customer's declared occupation, income sources, and purpose of the account. Cross-reference external data or OSINT to detect contradictions in background information that may arise when customers are recruited as money mules through fake job offers, romance scams, or other deceptive tactics.

Systematically verify identity documents and customer details during onboarding by cross-referencing addresses, phone numbers, and other identifiers across accounts to detect duplicates or forgeries. Confirm beneficial ownership to prevent criminals from repeatedly opening accounts using falsified credentials or proxy individuals. This approach addresses the vulnerability of mule accounts created with fraudulent or overlapping information.

During onboarding and periodically thereafter, verify the identities of individuals using crypto ATMs, requiring validation of legitimate sources of funds for significant or frequent usage. Cross-check transaction volumes, deposit patterns, and geographic usage against declared customer profiles to identify potential irregularities indicative of money mule behavior.

Implement robust checks and automated solutions to verify official identity documents, cross-referencing personal details with governmental databases or reliable third-party sources. Confirm the authenticity of submitted documents by examining security elements (e.g., holograms, watermarks) or scanning for signs of alteration, preventing criminals from using forged identification or business paperwork.

During the onboarding of clients operating in heavily regulated sectors, require the submission of verifiable permits and certificates from recognized authorities. Validate these documents by referencing official registries or contacting regulatory bodies directly. This ensures that forged or illegitimate sector documents are uncovered before account opening or service provision.

Collect detailed cross-currency transaction information during onboarding and throughout the customer relationship, including the role of brokers and any cross-border flows. Substantiate declared business activities against transaction behavior to detect NEP's hallmark rapid fiat-crypto exchanges outside regulated channels.

When onboarding potential money transfer clients, verify the licensing status and the legitimacy of any claims about operating a remittance or family-based transfer service. Cross-check business registrations, investigate the source of funds, and validate stated transaction corridors. This ensures hawaladars cannot masquerade as regular customers.

Require full identification of ultimate beneficial owners, screen for nominee arrangements, and cross-check trade licences or leases with public registries; accurate BO verification removes the anonymity that front companies rely on.

During the onboarding of call-center entities, require official proof of their operational setup (e.g., virtual or physical office leases, verified phone lines, staff rosters) and validate beneficial ownership. Cross-check any declared telemarketing or customer-support contracts with external data sources to confirm that purported earnings align with legitimate call-center services rather than fictitious billing.

Require comprehensive validation of each customer’s tax status, including collecting official tax identification documents and verifying reported income against reliable external data sources during onboarding. Confirm the individual tax obligations of beneficial owners and verify that entities are not systematically filing zero or minimal returns. This ensures that declared financial information is consistent with actual operations.

Require multi-factor authentication, biometric verification, or additional corroborating documentation for customers who frequently access services via anonymizing networks. These measures confirm the true identity and location of users, mitigating the risk that criminals hide behind Tor, VPNs, or proxies to obscure transaction trails.

At onboarding, require enhanced identity verification for sign-ups initiated via public WiFi, including real-time document checks and secondary address confirmation. By demanding stronger proofs of identity from applicants connecting through open or anonymized networks, institutions can reduce fraudulent account openings that leverage untraceable IP addresses.

Perform thorough identity verification for all senders, even for smaller amounts, by validating ID documents against external or official databases. Implement processes that flag the repeated use of personal details (e.g., phone numbers, addresses) under multiple names. Assess the overall transaction volume rather than viewing each remittance in isolation, thereby preventing abuse of low-value thresholds.

Enforce stringent ID verification for new gambling-related accounts by requiring official photo identification, verification of payment method ownership, and cross-checking personal details with external databases. Detect synthetic or repetitive account information that indicates layering or stolen identity usage.

Implement advanced identity verification solutions, including specialized software to detect manipulated or forged ID images, verify embedded metadata, and cross-check official records to confirm validity. By focusing on document authenticity and verifying real-time issuance data, institutions can identify synthetic or stolen identities before account opening.

Implement advanced identity verification procedures during onboarding, such as real-time document authentication by checking holograms, watermarks, and digital signatures, as well as biometric matching. Cross-check data against issuing authorities or third-party verification services, and compare details like photos and addresses with known watchlists or internal records to detect forged, stolen, or mass-produced documents.

APIs into national e-ID registries pull the authoritative spelling during onboarding; any deviation between user-submitted text and registry response halts account creation.

Require full disclosure of all existing or newly acquired nationalities during onboarding. Verify each passport or ID document for inconsistencies, assessing the customer’s rationale for holding multiple citizenships, especially from high-risk or CBI jurisdictions, to detect misuse of parallel identities or obfuscated beneficial ownership.

Require thorough verification of the underlying bank account and beneficial ownership when a customer seeks virtual IBAN services. Confirm the legitimate business purpose for each virtual IBAN issued, ensuring consistency with the customer’s declared operational activities. This measure ensures transparency over the actual account holders behind ephemeral IBAN references, deterring misuse for layering.

Require newly formed or high-volume e-commerce merchants to provide verifiable business documentation, domain registration details, and shipping or fulfillment records. Confirm that products offered match actual inventory and correlate with the merchant’s stated line of business to prevent sham storefronts and inflated sales.

Conduct thorough verification of the stated employer and wage data before underwriting a payroll deduction loan. Cross-reference official pay stubs, employer confirmations, or third-party payroll documentation to ensure repayment amounts align with the customer's legitimate salary. This prevents criminals from using fictitious or inflated payroll schemes to launder illicit funds.

Require legal or accounting professionals managing client funds to disclose and verify all underlying beneficial owners, disallowing professional privilege as a basis to withhold identity details. Cross-check the provided ownership data with registries or external sources, ensuring anonymity is not maintained behind claims of confidentiality.

Require customers transacting with self-hosted wallets to disclose their wallet addresses and provide cryptographic proof of ownership, such as a signed message. Cross-reference these addresses against known high-risk or watchlisted addresses to reduce anonymous inflows and outflows. By formally documenting the link between a customer and a self-hosted wallet, institutions strengthen traceability.

Identify the business's beneficial owners and verify the authenticity of its operations before accepting capital contributions. Compare declared sources of investment funds with the company's historical performance and industry norms to detect potential infiltration of illicit capital.

Require comprehensive customer identification and verification before establishing pension or superannuation accounts. Confirm declared income sources and verify the authenticity of listed beneficiaries. Institutions should validate each contributor’s background, ensuring that high-value or frequent deposits are consistent with legitimately documented income and that designated beneficiaries are genuine.

Mandate in-person or high-security identification for individuals who will operate accounts on behalf of others. Obtain notarized Power of Attorney (PoA) or representation documents, ensuring they comply with local regulations.

Collect and verify detailed information on both senders and recipients, confirming the stated familial or charitable relationship. For declared charity beneficiaries, validate registration status and legitimacy through official databases or public sources. Scrutinize gift letters for consistency with the customer’s known profile and ensure they align with credible documentation of personal ties or philanthropic involvement. By verifying these details upfront, institutions prevent criminals from misrepresenting the true purpose of remittances.

Require customers to explain the source of funds used to purchase or acquire the bearer instrument, especially if the amount is large. Cross-check the explanation with the customer’s profile, financial history, and risk rating.

Require transparent disclosure and verification of the crowdfunding campaign’s ultimate owner or beneficiary, such as through official ID checks or proof of charitable status, to prevent criminals from concealing their identities under fake profiles or opaque entities.

Collect and verify documentation evidencing a legitimate business purpose, market-consistent valuations, and proper ownership for jewelry transactions at onboarding and during periodic reviews. Cross-check declared values against recognized gemological references or industry price benchmarks to detect over- or under-reported valuations.

During onboarding and periodic reviews, require formal confirmation of tobacco licenses, import permissions, and excise tax receipts. Verify that transaction volumes align with legitimate tobacco market expectations, detecting anomalies such as unexplained surges in purported cigarette sales or shipments to jurisdictions with known tax arbitrage issues.

At onboarding, validate the identities and official roles of public-sector customers with budgetary authority, ensuring full documentation of their duties and any external business affiliations. For accounts linked to government agencies, explicitly confirm the authorized signatories’ credentials. By scrutinizing the legitimacy of public-official customers from the outset, financial institutions reduce the likelihood of unknowingly accommodating channels for misappropriated public funds.

During onboarding and periodic reviews, request detailed payroll structures from businesses operating in cash-intensive sectors. Compare officially reported staff rosters or wage statements against the frequency and volume of cash withdrawals to identify hidden or under-the-table wage payments.

During onboarding and periodic reviews of labor-intensive businesses, require verifiable employee rosters and payroll documentation. Compare declared headcounts with registered tax, insurance, or regulatory data to detect discrepancies that may indicate off-the-books wage payments to undocumented workers.

Perform comprehensive identification and verification of all depositors, particularly those who are not the named account holders, ensuring each deposit is traceable to a legitimate source. Cross-check the geographic distribution of deposits against a customer’s stated business or personal profile to detect and escalate irregular sub-threshold placements.

Require verified identification for TITO redemptions or high-value cash transactions above defined thresholds. Perform risk-based assessments on frequent or large TITO redeemers to verify the source of funds and confirm legitimate gambling activity. Enforce maximum redemption limits without verified identity to prevent structuring through multiple sub-threshold transactions.

Verify the identity of donors or lobbying service providers by capturing the beneficial ownership of corporate donors or philanthropic nonprofits. Cross-reference the provided details with official campaign finance registries and industry data to confirm the legitimacy of the donations or lobbying activities. This process helps uncover disguised foreign or corporate donors or bribery attempts hidden behind legitimate political support.

For environmental or natural resource traders, confirm the authenticity of business registration, licensing, beneficial owners, and physical operations. Cross-check official government or NGO databases to identify front or shell companies that could be used to channel illicit environmental proceeds into legitimate trade flows.

During onboarding and periodic reviews, validate customers claiming adult entertainment income or other sex-industry revenues by requiring business permits or relevant documentation, verifying the nature of services offered, and confirming registered addresses. Compare declared income sources with transaction volumes to identify mismatches that may indicate possible forced prostitution or child sexual exploitation proceeds.

During onboarding and periodic reviews, verify the legal status of any adult claiming to act on behalf of a minor. Corroborate the legitimacy of guardianship or charitable operations involving children, and check for inconsistent or fabricated identification documents. Confirm that funds ostensibly benefiting minors are channeled through transparent, verifiable structures, ensuring no hidden facilitators funnel revenues from child exploitation into legitimate financial products.

Perform thorough identity checks, verify claimed business operations, and request additional documentation when customers exhibit cross-border or cash-heavy activities suggestive of smuggling. Confirm the legitimacy of frequently used travel or immigration service references, and ensure beneficial owners are transparent and verifiable.

Require transparent disclosures of all beneficial owners for new accounts in private or pooled investment vehicles. Verify entity documents, personal identifications, and sources of funds for each significant investor to ensure that no undisclosed parties or suspect fund origins are hidden behind layered corporate structures. This foundational step blocks criminals from exploiting anonymity at account inception.

Obtain and verify all relevant information for bond purchasers, ensuring that declared identities and funding sources match official records. Confirm the legitimacy of each acquisition by comparing the investor’s stated wealth and investment profile with the scale and frequency of bond purchases, flagging any mismatches for immediate review.

Require robust, upfront identity verification steps for prepaid card or digital wallet applicants, particularly when products originate from offshore issuers. For example, mandate validation of provided identification through official government databases or credible external sources, and reject accounts that do not conclusively verify legal identity. This prevents criminals from leveraging low-tier or forged documentation commonly used to open these offshore accounts.

Require mandatory identity verification at crypto ATMs for transactions exceeding designated low-value thresholds, using officially recognized documents or biometric solutions. Maintain customer profiles that link transaction histories to prevent repeated anonymous usage and flag unusual behaviors indicative of layering or structuring.

Implement robust identity checks and beneficial ownership verification for customers engaging in NFT transactions, especially where high-value NFTs or repeated flipping is observed. This directly addresses minimal KYC vulnerabilities in NFT marketplaces by ensuring the true owners behind NFT wallets are identified, reducing the anonymity that facilitates NFT-based layering.

Require verifiable user identification for customers participating in high-volume or frequent virtual currency transactions. Collect and validate IP addresses, gaming profile details, and any related digital wallet information to ensure that individuals moving significant in-game values are not exploiting platform anonymity or incomplete KYC processes.

Require detailed customer information during account onboarding for metaverse-related activities, including intended transaction volumes, platform usage, and relevant geographic nexus. Verify beneficial owners for entities trading high-value digital assets and confirm the legitimacy of any large crypto holdings introduced to the account.

Require comprehensive identity verification for customers engaging in cross-platform or external RMT transactions. Confirm consistent ownership across gaming accounts to prevent misrepresentation or the use of straw accounts. This counteracts criminal attempts to obscure account ownership when shuttling value through unregulated channels.

Implement robust identity and beneficial ownership checks for customers engaging in frequent in-game currency purchases or conversions. Require verification of payment sources, such as credit cards and crypto wallets, to ensure they are not stolen or misrepresented. This prevents anonymous or fraudulent funding of gaming accounts and provides a clear audit trail for large or unusual in-game transactions.

Require customers to declare all relevant wallet addresses, bridging protocols, and intended token usage. When high-volume or rapid bridging is observed, verify legitimate ownership and the source of funds (e.g., business records, contracts). This reduces anonymity in decentralized platforms by establishing a transparent link between customers and their token activities.

Gather and verify identifying information from clients initiating or receiving payment token transfers, ensuring they meet minimum KYC standards. Confirm that customers’ declared source of funds aligns with their profile to prevent anonymous or poorly verified access to high-risk digital asset platforms.

Require detailed information about customers’ DeFi usage at account opening and during periodic reviews. Validate the economic or investment rationale for chain-hopping and identify ownership of self-custodial wallets used for staking, liquidity pooling, or yield farming to prevent misuse of anonymized or borrowed wallet addresses.

During the onboarding and renewal process, require official payroll records, employee tax IDs, and wage documentation to confirm the authenticity of a company's workforce. Cross-check these details with labor or tax databases to expose fabricated or inflated employee rosters, directly targeting ghost employee schemes.

During onboarding and routine reviews, verify that the customer’s shipping activities align with legitimate business operations by confirming physical premises, prior shipping history, and credible references. Corroborate their claimed trade routes or products with external data to ensure the cargo and shipment volumes are realistic.

Require prospective customers to disclose anticipated third-party depositors during onboarding and verify the identities of these external payers. Disallow transactions from unknown or unverified third parties, ensuring a fully documented chain of ownership to prevent anonymity in the payment flow.

Implement robust identity checks at account opening, including automated document scanning, biometric verification, and cross-referencing customer data with official databases to confirm authenticity. This directly combats identity impersonation by detecting forged or stolen documents before an account is fully established.

Implement robust digital ID checks incorporating liveness detection and document metadata analysis for remote onboarding. Cross-reference IP addresses, device fingerprints, and geolocation data to identify applicants reusing the same device or network under different identities. Require secondary validation, such as third-party or government databases, for suspicious inconsistencies.

During onboarding and throughout the relationship, verify the legitimate business purpose for cross-border foreign exchange transactions, confirm the beneficial ownership of all involved entities, and document each trading partner’s typical transaction volume. Detect irregularities such as recurrent over/under-invoicing or frequent currency conversions unrelated to the customer’s stated business.

Verify the identity of each account holder and authorized user, requiring documentation for multiple cross-regional transfers. Ensure that the nature of the business or personal activity justifies frequent inbound deposits from geographically dispersed sources. Investigate discrepancies or a lack of credible explanations to address funnel account risk.

Obtain verifiable documentation confirming an entity’s diplomatic mandate or state-ownership status. Validate the legitimacy of each authorized signatory and clarify the permissible scope of account usage. By establishing robust identity proof and legitimate purpose, institutions can deter personal enrichment or hidden corruption within privileged accounts.

Collect and verify payer information for each deposit to a financial product, confirming a legitimate relationship with the policyholder or account holder. Verify the source of funds when third-party contributions exceed standard requirements. This measure helps reveal unauthorized or suspicious overfunding attempts that may conceal illicit proceeds.

Require the explicit identification and verification of each policyholder, beneficiary, and any third-party payer. Confirm the financial capacity and legitimate relationship of premium payers to the policyholder, scrutinizing premium sources to detect inflated or layered payments. This ensures transparency at onboarding and helps prevent anonymity or hidden ownership structures exploited in early surrender schemes.

Require upfront identification and verification of all policyholders and beneficiaries, documenting the legitimate relationship and intended purpose of the annuity. Collect evidence of the source of funds for lump-sum or structured premium payments, and flag instances where third-party payers or beneficiaries have no clear connection to the policyholder.

At onboarding, confirm the identity of each beneficial owner and require documentation for ownership structures, including trust deeds or corporate registries. When changes in beneficial ownership occur, promptly request updated information and documentation, verifying the legitimacy of each amendment. This measure ensures baseline transparency, uncovering potential manipulation in official ownership records.

At the onboarding stage for securities accounts, collect and verify comprehensive beneficial ownership details and trading authority credentials. Confirm each party’s legitimate connection to the account to reduce the likelihood of hidden or proxy-controlled relationships from the outset.

During onboarding and throughout the policy lifecycle, require clear evidence of the legitimate origin of large or repeated premium payments. Validate the customer’s financial profile (e.g., income, assets) against the policy’s funding amounts and request supporting documents for significant overpayments or early surrenders, ensuring the insurance product usage aligns with the customer’s stated circumstances.

Require robust identification and verification of all trading accounts, ensuring disclosure of any overlapping beneficial ownership. For high-volume or frequently offsetting traders, demand documentation justifying trading activities to prevent covert self-dealing and market manipulation.

Require customers who declare ownership or control of high-value assets (e.g., shares, real estate) to provide verifiable government records or official documentation. Cross-check the disclosed asset details with public registries or other credible external databases to detect any unrecorded or hidden changes in ownership, thereby exposing off-the-record transfers that bypass official documentation.

When onboarding or transacting with individuals or small groups known to participate in informal micro-finance schemes, institutions require documentation and detailed explanations of the group’s membership, contribution cycles, and sources of individual contributions. This visibility helps detect irregular fund flows and uncovers attempts to blend illicit proceeds within legitimate group transactions.

Require documented proof of identity, financial standing, and asset ownership from both borrowers and lenders to confirm legitimate income sources and business operations. Conduct independent verification of financial statements, business activities, or personal guarantees. This mitigates typical loan-based laundering tactics, such as overstated revenues or non-existent collateral, by ensuring real, verifiable assets and solvency.

Obtain and verify the corporate registration documents and beneficial ownership details of consulting or management service providers. Require evidence of actual operations, such as office address, staff, and service references, to ensure the entity charging service fees is a legitimately functioning business rather than a front or shell company.

Collect and verify robust identification data for all crypto-focused clients, ensuring that wallet ownership and transaction patterns align with declared economic activities. Cross-check wallet addresses against Darknet-related watchlists or known mule accounts to minimize the anonymous use of institutional platforms for illicit trade.

During onboarding and periodic reviews, verify the beneficial ownership of each trading account and cross-reference it with existing client records. Confirm that there are no overlaps or hidden links that enable simultaneous buy-sell orders lacking economic purpose, which is a hallmark of wash trading.

Require robust identity checks for loyalty program membership where substantial point balances or transfers are possible. Gather verifiable personal or corporate details to ensure points cannot be purchased or moved through anonymous accounts, and regularly update customer data as point usage evolves.

For online or in-person gambling accounts, require official identity documentation and cross-check high-value or frequent bettors against adverse media and watchlists. Verify declared funding sources for substantial buy-ins or top-ups to prevent the anonymous introduction of illicit proceeds.

During onboarding or periodic reviews, verify customer claims of lottery winnings with official lottery data. Cross-check ownership details, draw dates, and prize amounts to confirm that the purported winnings match legitimate ticket records. For larger or repeated claims, require documentation of ticket purchase and redemption processes to detect the use of nominees or front companies, which is common in lottery-based laundering.

Require robust identification and verification for all gambling accounts, ensuring that each user provides valid documentation and verified payment sources. This deters launderers from exploiting minimal KYC to open multiple fraudulent accounts or deposit and dump chips through stolen credit cards.

Collect and verify detailed customer identification whenever individuals buy or redeem chips beyond established thresholds. Require clarity on the source of funds for large or repeated transactions to mitigate the risk of anonymous high-value play that conceals illicit proceeds behind purported gambling funds.

Obtain evidence of legitimate gambling activities, such as official payout slips or documents from recognized operators, when customers claim substantial winnings. Scrutinize individuals who present frequent cash balances without supporting records, and reclassify them as higher-risk if they cannot demonstrate that their gambling proceeds originate from licensed venues.

Require all prospective real estate auction participants—both individuals and corporations—to undergo thorough identity verification, including proof of beneficial ownership for corporate bidders. Validate the source of funds, especially in cases of large cash payments, to prevent the use of straw buyers and the infiltration of undisclosed beneficial owners.

Collect detailed documentation on clients’ reasons for frequent currency conversions, verify the legitimacy of cross-currency transactions, and identify beneficial owners for legal entities involved. Investigate any unusual or unexplained changes in exchange volume or denominations.

During onboarding, collect and verify information about the customer's need to use RDC, their typical check amounts, and expected counterparties. Corroborate the legitimacy of payees and endorsees, especially where large or frequent checks are deposited remotely, to detect inconsistencies that may indicate fraudulent deposit practices.

Obtain and verify membership credentials or philanthropic claims during account onboarding, ensuring each member’s identity and declared financial activities align with the cooperative’s stated purposes. Explicitly confirm the legitimacy of membership references, documented community mission statements, or charitable efforts to prevent the misuse of minimal documentation for depositing illicit proceeds.

Require direct identification and verification of any local intermediaries or sub-agents opening accounts on behalf of ultimate beneficial owners. Collect evidence of the agent’s authorization and gather supporting documentation for multi-jurisdiction relationships, focusing on establishing legitimate control of accounts to prevent local fixers from concealing beneficial ownership structures.

Collect verifiable proof of operational capacity, such as documented payroll, call-center logs, or genuine online transaction invoices, from virtual businesses during onboarding. Investigate and confirm the identity of each listed controller or beneficial owner through official identification and corroborating digital footprints to ensure legitimacy.

Enforce rigorous corporate onboarding procedures for prospective M&A participants, requiring official registration documents, verified beneficial ownership data, organizational charts, and proof of operational history. Confirm that the stated purpose of the merger or acquisition aligns with the customer’s actual business scope to detect contrived or shell-based setups commonly used in fictitious M&A transactions.

Require comprehensive documentation on the nature and source of high-value assets intended for freeport or private storage. Verify the true owner(s) and confirm alignment with the customer’s known wealth and economic profile. By establishing transparency at onboarding and throughout the relationship, institutions mitigate risks associated with anonymous asset holding and the potential disguise of illicit proceeds.

Incorporate verification of real estate broker licensing as part of standard customer onboarding and transaction reviews for property deals. If brokers are not found in official databases, require additional information from the customer about the broker’s background and verify the source of funds for both parties to block illicit money inflows.

Enforce robust identity verification (e.g., government-issued IDs, address cross-checks) for customers using prepaid cards or mobile-based remittance services. Immediately suspend or restrict usage if required CDD data is incomplete or inconsistent to prevent anonymous layering and placement via these channels.

Perform robust identity verification during P2P account onboarding by collecting official IDs, selfies, or biometric data. Cross-check identifying information for consistency and confirm beneficial ownership for high-volume or business-related P2P accounts. This measure addresses minimal or nonexistent KYC risk in P2P channels and reduces the anonymity exploited by criminals.

Implement rigorous remote identity verification for mobile payment account openings, including real-time device validation, live photo or video checks, and proof of phone number ownership. Confirm the legitimacy of each customer's identity credentials to close common entry points for layering.

Implement robust remote ID document checks and biometric liveness testing. Cross-verify user-submitted data against official databases or trusted third-party identity services. Enforce device fingerprinting to detect repeated submissions from the same device under different identities.

Require official registration papers, business licenses, and tax identification for all claimed commercial activities during onboarding. Compare the provided documents against government or third-party sources to detect unreported business activities or incomplete financial disclosures.

During account onboarding, verify identities and account intentions by cross-checking applicants' stated purposes for the account with reliable documents and data sources. Investigate any indirect references to job offers or third-party use of the account to detect potential mule recruitment before activation.

• Require evidence of legitimate employment for individuals claiming remote or payment-processing job roles.
• Verify employer details using official business registries or external sources before permitting high-volume transfers in personal accounts.

Obtain and verify foundational customer information, including ultimate beneficial ownership, from the outset, particularly for clients or accounts with geographic ties to sanctioned or thinly regulated jurisdictions. By confirming customer identity and examining ownership structures early, institutions can detect or block sanctioned entities from accessing financial services under false pretenses.

Verify the authenticity of a customer’s declared commodity trading activities by reviewing beneficial ownership details, matching claimed products with relevant trade permits, and confirming logistical capacity (e.g., dedicated warehouses, staff). This ensures early detection of front companies or inexplicable import/export practices commonly associated with illicit commodity dealings.

Obtain and validate detailed information from businesses dealing in medical products, ensuring legitimate pharmaceutical licenses, proof of authorized distribution, and appropriate business addresses. By verifying legitimacy during onboarding, institutions can block counterfeit pharmaceutical operators from accessing financial services.

Conduct thorough identity and business verification from the outset, targeting red flags such as contradictory legal documents or nonexistent corporate addresses. Cross-reference client data with public records and watchlists to ensure the individual or entity is not using sham credentials to claim eligibility for government funds or to submit forged invoices. CDD prevents fraudulent actors from easily onboarding under false pretenses to launder newly created illicit proceeds.

Obtain and verify official authorization documents or grant notices during account setup or when receiving program funds. Confirm that the declared business or individual actually qualifies for the relief program by cross-referencing corporate registration data, unemployment or subsidy approval records, and any additional required certifications. This ensures that criminals cannot easily deposit proceeds from falsified relief applications without detection.

Perform thorough identity and business verification on relief fund applicants by cross-checking registration records, validating beneficial ownership, and confirming actual operational history. Specifically, verify newly formed or reactivated businesses claiming large downturns, ensuring that claimed employee rosters and historical activity align with official filings or registries. This helps expose forged or synthetic identities and prevents fraudulent relief claims at onboarding.

During onboarding, verify declared VAT or tax-exempt status, confirm legitimate business activities and operational presence (e.g., tangible offices, staff, or inventory), and cross-check historical trade records for consistency. This ensures foundational transparency, preventing the use of ephemeral or shell companies to cycle goods and claim illicit VAT refunds.

Require documentary proof (e.g., prior wage statements, termination letters) from customers receiving unemployment benefits and cross-verify these records against official or publicly available data sources. This ensures the claimant’s eligibility aligns with their stated unemployment status and reduces the risk of disbursements based on stolen or fabricated identities.

Require thorough identity verification of new account holders, including verifying the authenticity of identification documents and cross-checking customer details with fraud databases to detect stolen or fabricated identities frequently used in cheque fraud. Additionally, confirm the legitimacy of payors for large or unusual checks to ensure alignment with the customer’s stated profile.

Require detailed verification for accounts soliciting charitable donations on social media. Demand proof of legitimate nonprofit registration or partnership, such as official documentation or tax-exempt certificates. Cross-check beneficiary information with recognized charity databases to ensure that the account is not merely a newly opened personal account collecting funds under false pretenses.

Require agricultural subsidy recipients to provide official farmland registration documents, production records, and beneficial ownership details. Cross-verify submissions with local land registries and agricultural databases to detect fabricated farmland claims and identify potential straw owners seeking fraudulent subsidies.

Require thorough identification and verification of large contributors in token sales, especially when deposits originate from newly generated or unverified wallets. Scrutinize the source of funds and ownership details for any high-value or repeated contributions to detect attempts at layering illicit capital through the offering.

During onboarding, require proof of lottery-focused licensing, corporate registration, and business purpose for any organization claiming to operate a sweepstakes or lottery. Validate identities and ownership details to detect fictitious entities or individuals exploiting advanced fee fraud setups.

During account onboarding or periodic reviews for businesses claiming payroll or unemployment-related transactions, systematically verify the employer’s registration status, operational presence, and payroll obligations with relevant government databases and external records. Cross-check that reported employees actually exist in identity sources and that claimed wages align with typical HR or industry norms. This directly targets fictitious employers who submit fraudulent benefit claims.

Require verification of a promoter’s identity, licenses, business model, and financial track record. For crypto-based ventures, confirm token contract authenticity and review any claimed code audits. By ensuring legitimate background information, institutions reduce the risk of onboarding fraudulent or unregistered investment schemes.

Obtain detailed information on company principals active in timber exports, verifying their identities, business rationale, and operational history. Cross-verify beneficial ownership declarations with official records to detect shell companies that mask ownership of illegal logging profits.

• Confirm each customer's claimed authority to trade in wildlife by verifying relevant licenses, such as CITES permits.
• Verify beneficial ownership.
• Match standard business operations to declared wildlife activities.
• Escalate accounts that hide or misrepresent their involvement in high-risk species trade.

Obtain and verify accurate personal or business information from customers likely to deposit smaller amounts of cash. Cross-reference stated business activities with expected revenue levels to identify discrepancies that might indicate proceeds from street-level crimes. This measure ensures that only legitimate sources of income are accepted and documented from the outset.

At account opening and periodically thereafter, collect and verify details about a client’s declared income, tax residency, and beneficial ownership. Compare these disclosures with official registries or verified external information. Such checks can reveal mismatches or undisclosed assets that may flag potential underreporting of taxable funds.

During onboarding and periodic reviews, systematically verify the business's actual workforce size and payroll details against official tax or insurance records. This helps detect underreporting or shell structures used to conceal wages, ensuring declared payroll obligations align with real operational data.

Require legitimate tax registration documents and proof of genuine business operations before accepting or processing rebate-related funds. Validate the customer's capacity to generate such refunds, ensuring that beneficial owners and claimed business activities conform to actual reported tax filings.

Require thorough verification of beneficial ownership for trades involving dividend-bearing securities. Document share entitlements, confirm that multiple parties are not claiming the same dividend, and correlate ownership data with official registries or clearinghouses to identify contradictory filings.

During onboarding and periodic reviews, verify the operational reality of export-focused clients by assessing facilities, transaction histories, and beneficial owners. Inconsistencies between declared export figures and the company’s demonstrated capacity should trigger closer scrutiny for inflated invoicing exercises.

During onboarding and ongoing reviews, validate a customer’s stated sources of cryptocurrency income against external evidence of legitimate mining operations. Cross-check power usage, hardware ownership, and mining pool affiliations to rule out unauthorized cryptojacking, where minimal operational indicators, such as electricity bills, often contradict claimed mining revenues.