Enhanced Customer Due Diligence

Enhanced customer due diligence is required in situations with a higher likelihood of money laundering and terrorist financing occurring as determined by AUSTRAC and the Financial Action Task Force (FATF).

When Enhanced Customer Due Diligence is needed

With 2Shakes you get a checklist of factors for Enhanced Customer Due Diligence. If you select one, 2Shakes records the CDD level as Enhanced. 2Shakes also provides ‘help’ to suggest what you should do.

Where the money came from (Sow & SoF)

The key difference between Standard CDD and Enhanced CDD is you ALSO need to identify where the money came from. This is know as the Source of Wealth (SoW) or Source of Funds (PoF). For example, if a Trust owns a house, it might be the sale and purchase agreement. If the Trust owns shares in a business, then it might be the companies financial accounts.

2Shakes allows you to record when SoW or SoF has been collected, what it was, and then securely store it. Examples of SoW/SoF can include:

Salary or wages: Payslip summary or employer letter confirming employment and salary details
Sale of a property: Sale record or title deed from the sale of property
Deceased estate (a letter from the executor of an estate confirming the distribution of assets to the customer as inheritance
Signed letter from the client’s certified practicing accountant confirming their source of funds
Reliable and independent online sources such as government databases and credible media reporting

Our CO reviews all SoW/SoF documents and records their assessment of them using Notes and Files.

Checking its all in order

2Shakes lets you see at any point in time what state a customer’s CDD is in. You can see what is outstanding, which people haven’t completed identity verification, if PEP checks are missing, or if you’re missing source of funds.

For Enhanced CDD, make sure you consider the following:

Have you identified and recorded where the customer’s Wealth or Funds come from. Have you sighted or uploaded a copy of the SoW or PoF.
Has Identity verification been completed for all people. Have you completed address verification and PEP checks for all people
Has the Risk Assessment and the ‘Nature of Business’ been collected and recorded.

The Compliance Officer can then review the CDD information, and approve it as completed, so you can provide the Trust with AML captured services.

More Help

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