Enhanced Due Diligence (EDD) for High-Risk Customers
When standard due diligence is not enough, the law demands more. We build the enhanced measures your business must apply to high-risk customers, so you meet the heightened standard the PCMLTFA requires.
When Standard Due Diligence Is Not Enough
Enhanced due diligence applies where risk is higher than normal: politically exposed persons, customers in high-risk jurisdictions, unusual transactions, and complex ownership. In these situations, standard identification does not satisfy the PCMLTFA. You must dig deeper, and document why you are satisfied the relationship is legitimate.
Source of Funds and Source of Wealth
The heart of enhanced due diligence is understanding where money comes from. We help you establish both source of funds, the origin of the specific money involved, and source of wealth, how the customer accumulated their assets overall. Verifying both, with evidence, is what separates genuine enhanced diligence from a box-ticking exercise examiners see through.
Risk Triggers
We define exactly when a customer or transaction triggers enhanced due diligence.
PEP Screening
We build the process to identify politically exposed persons and their close associates.
Source Verification
We establish how you verify source of funds and source of wealth with evidence.
Senior Approval
We build the senior sign-off high-risk relationships require before you proceed.
Ready to Simplify Your Compliance?
Businesses We Support With EDD
We build enhanced due diligence for money services businesses, payment providers, cryptocurrency platforms, currency exchanges, real estate firms, and the many other reporting entities that onboard higher-risk customers under the PCMLTFA.
We support banks with program design, oversight, & regulatory examination readiness.
We help credit unions meet obligations proportionate to their membership and scale.
We handle registration, renewals, reporting, & controls FINTRAC expects from you.
We cover Bank of Canada registration alongside your anti money laundering obligations.
We establish what your wallet activity triggers, then build only what applies.
We build compliance around what your product does, before volumes and questions arrive.
We register virtual currency dealers and build the reporting their activity demands.
We support financial institutions across registration, program build, and reporting duties.
Why Businesses Choose Our Approach
Clear Triggers
We define precisely when enhanced measures apply, so your staff know exactly when standard checks are no longer enough.
Genuinely Evidenced
We build source of funds and wealth checks that stand up to scrutiny, not superficial questions with unverified answers.
Defensible Decisions
We document why each high-risk relationship was approved, so your decisions hold up under examination and audit.
Serving Businesses Across Canada
We build enhanced due diligence right across the whole of Canada, from Toronto and Montreal to Vancouver and Calgary, and for foreign reporting entities carrying Canadian obligations wherever they operate.
Let's Talk About Your Compliance Needs
Schedule a Free Consultation
Whether you’re starting a new MSB or need ongoing AML support, our team responds within one business day.
Enhanced Due Diligence Questions
Clear answers to the questions Canadian businesses ask most about applying enhanced due diligence to high-risk customers under the PCMLTFA.
What triggers enhanced due diligence?
Higher-risk situations: politically exposed persons, high-risk countries, unusual or complex transactions, and any relationship your risk assessment rates as high.
How does EDD differ from CDD?
Standard due diligence identifies the customer. Enhanced due diligence goes further, verifying source of funds and wealth and applying closer, more frequent monitoring.
What is a politically exposed person?
Someone holding a prominent public position, along with their family and close associates, who carries a higher risk and requires enhanced measures.
Must we verify source of funds?
For high-risk relationships, yes. You must establish and evidence both where the specific funds came from and how the customer built their wealth.
Who approves onboarding high-risk customers?
Senior management should approve onboarding or continuing high-risk relationships, and that approval should be documented as part of your enhanced measures.