Enhanced due diligence

Higher risk can arise from the customer, the ownership structure or the transactions being examined. Under Section 15 of the German Money Laundering Act, additional measures supplement general customer checks and depend on the relevant circumstances. Politically exposed persons and certain high-risk country relationships have specific requirements under the applicable rules.

An unusual transaction needs investigation of the background and economic purpose before the institution reaches a conclusion. A complex structure can have a legitimate explanation that the reviewer should examine in the case file. Teams must distinguish an unresolved risk indicator from verified facts about the customer and the proposed activity.

Regulation (EU) 2024/1624 generally applies from 10 July 2027 and establishes the EU anti-money laundering rulebook. The regulation includes additional customer measures, while the EU AML package also addresses supervision and national institutional arrangements. Institutions need to compare the future requirements with the rules already applicable to their activities.

AMLA submitted final draft private-sector standards to the European Commission on 1 October 2026. The AMLA draft standards require adoption and publication before becoming binding delegated legislation. Their proposed application arrangements must remain separate from the application date established in the regulation.

For crypto-asset services, an investigation can connect a customer explanation with observable transfers on a supported blockchain. EBA guidance for crypto-asset service providers includes blockchain analytics among the measures used to manage money laundering risks. Analysts should establish which networks and transaction types the selected tool actually covers.

A practical review can compare transaction hashes and transfer times with exchange records supplied by the customer. Investigators should record the basis and date of any service attribution attached to an address. An exposure score needs interpretation alongside the customer evidence and the limits of the available attribution.

A relationship graph can organize the companies, people and accounts appearing in an investigation. Links between those records need a stated source and a clear meaning. A shared address may explain a possible connection, while verified ownership requires evidence supporting that separate conclusion.

Investigators can use KYB verification to examine corporate identity and beneficial ownership before reviewing financial flows. The graph should retain uncertain matches separately from relationships supported by reliable records. A reviewer then decides which missing ownership information requires further investigation or customer clarification.

FATF guidance on new technologies for AML addresses advanced analytics alongside implementation and data-protection constraints. In an EDD workflow, machine assistance can organize case evidence or prioritize information for investigation. Teams should test whether every generated statement can be traced to the underlying source.

A case summary should preserve conflicting evidence and explain why a reviewer accepted or rejected a proposed conclusion. AI in anti-money laundering therefore needs a defined review process and documented operational limits. Where senior approval is required, the approval record should identify the decision maker and the evidence considered.

An implementation checklist should start with the risk trigger and the additional questions that trigger creates. The team then assigns evidence requests to the responsible investigator and records what remains unresolved. Evidence about the origin of a payment should be distinguished from an explanation of accumulated wealth.

Before selecting a system, buyers can test a case containing conflicting ownership information and an uncertain address attribution. The test should show how an investigator corrects an assumption and how the correction reaches the approval queue. Buyers should also check whether reviewers can retrieve the evidence supporting an earlier decision.

Higher-risk relationships need continuing review suited to the reasons for the elevated risk. Transaction monitoring can provide investigation triggers when observed activity departs from the expected relationship. A new beneficial owner or an unexplained change in payment patterns can require the customer file to be reassessed.

Teams should define which changes reopen the investigation and who decides the required response. A completed screening task does not answer every question raised by the wider relationship. The continuing review should connect new evidence with the existing rationale for accepting the customer.