Customer due diligence

The EU anti-money laundering regulation generally applies from 10 July 2027 and sets customer due diligence requirements. Identification, beneficial ownership and understanding the relationship belong to a wider assessment of the customer.

AMLA submitted final draft customer due diligence standards to the European Commission on 1 October 2026. Those drafts require adoption and publication before becoming binding delegated legislation.

A customer due diligence checklist should connect each required check with evidence and an accountable reviewer. For a corporate customer, teams need to distinguish the company from the people controlling or representing that company. KYB verification establishes ownership and representation information within that wider customer assessment process.

Implementation teams can record which evidence supports each finding and which information remains unresolved. The resulting customer file should explain the decision without requiring an analyst to reconstruct unrelated system logs.

The European Digital Identity Wallet framework supports proving identity and sharing specific personal attributes across services. An EUDI Wallet for financial services therefore concerns the identity evidence entering the customer process.

An institution should compare the attributes received with the information needed for that customer. Missing attributes need a defined collection and verification route before the case advances. AMLR identity verification requires permitted evidence, with qualifying electronic identification meeting substantial or high assurance levels.

Identity orchestration connects verification results with customer records and the teams making acceptance decisions. A useful evidence record identifies the source, collection time and check supporting each verified attribute. Conflicting results need an explicit review path before an automated workflow treats the customer file as complete.

Stripe Identity tracks verification through persistent verification sessions, including failed checks and requests for further input. That implementation example illustrates state management within one verification step of the wider customer assessment.

The Basel Committee framework for money laundering risk management connects customer risk profiles with ongoing monitoring. Customer information needs review as the relationship changes and new evidence affects the original assessment.

Perpetual KYC can connect incoming changes with the customer checks requiring attention. For example, a changed ownership record should prompt an assessment of the affected corporate customer. An institution should document whether the event requires updated evidence, a new risk assessment or escalation.

Customer due diligence software needs to preserve the reason behind each review and escalation. Investigating a screening match establishes whether the result concerns the customer under review. AML transaction monitoring contributes evidence about activity after the customer relationship begins.

Higher-risk cases can require additional evidence and approval through enhanced due diligence. The difference between KYC and AML helps separate customer checks from the wider prevention framework. Automation should route unresolved information to a responsible reviewer with the evidence needed for a decision.

Procurement teams can ask providers to demonstrate one complete customer case across the proposed workflow. The demonstration should include interrupted verification, contradictory attributes and a later change in ownership. Reviewers should be able to retrieve the evidence and decision history for each stage.

Access controls and retention settings also need assessment against the applicable obligations and customer information involved. A successful demonstration establishes specific system behavior without proving compliance with every applicable requirement.