An enhanced due diligence checklist covers the extra steps for a higher-risk customer: why EDD applies, source of wealth, source of funds, purpose of the relationship, deeper adverse media, PEP details, ownership, an interview where needed, senior approval and enhanced monitoring. An AI agent can gather and organise the evidence. Every judgement and the approval stay with people.
What is the checklist for?
Enhanced due diligence is what you do when standard customer due diligence is not enough because the risk is higher: a politically exposed person, a high-risk country, a complex structure, unusual activity. The FATF Recommendations expect enhanced measures in such cases under a risk-based approach; your local rules set out when they are mandatory.
EDD is where evidence-gathering is heaviest and judgement matters most. An agent can search registries, read documents, compare stated wealth with public information and draft the file. Whether the story holds together is a different question, which is the argument of enhanced due diligence still needs a person.
When should it be used?
Open the checklist when a customer's risk rating reaches high, when an override applies (for example a PEP), or when a trigger event raises risk for an existing customer. Complete it before onboarding or before continuing the relationship, and repeat the relevant parts at each review. The full process is in how to run enhanced due diligence on high-risk customers with an AI agent.
How do you complete each item?
For each item, record the finding, the evidence and its provenance, who completed it, and whether the item is satisfied. Two items carry the most weight.
Source of wealth explains how the customer came to have their overall wealth: career, business sale, inheritance. Source of funds explains where the specific money for this relationship comes from. Both need evidence beyond the customer's word. A customer's statement is declared; a sale contract, probate document or audited accounts can be signed or verified.
Where the agent finds information that contradicts the customer's account, it records both and flags the conflict. It does not decide which is right.
The enhanced due diligence checklist
| No. | Item | Agent may | Person decides |
|---|---|---|---|
| 1 | Reason EDD applies | Record trigger and rating | Confirm scope |
| 2 | Purpose and intended nature of the relationship | Record customer's account; compare with products requested | Accept purpose |
| 3 | Source of wealth | Gather documents and public records; build a timeline | Judge plausibility and sufficiency |
| 4 | Source of funds for initial and expected deposits | Match funds to documents | Judge sufficiency |
| 5 | Expected activity: volumes, counterparties, countries | Draft profile from customer's account | Set thresholds for monitoring |
| 6 | Politically exposed person details | Record position, dates, relationship | Assess risk of the position |
| 7 | Ownership and control | Link to ownership checklist results | Confirm |
| 8 | Adverse media, wider search | Search in relevant languages; summarise | Judge relevance |
| 9 | Independent verification of key facts | Request third-party confirmations | Accept |
| 10 | Interview or meeting | Prepare questions from gaps | Conduct and record |
| 11 | Overall assessment | Draft summary of evidence and gaps | Write assessment |
| 12 | Senior management approval | Approve or decline | |
| 13 | Enhanced monitoring rules | Propose rules from the expected profile | Set rules |
| 14 | Review frequency | Record policy cycle | Confirm |
A filled sample
A hypothetical customer, the adult child of a serving senior official, opens an account to deposit 400,000 from a property sale.
| No. | Finding |
|---|---|
| 1 | Family member of a PEP; rated high |
| 2 | To hold sale proceeds and buy a new home within a year (declared) |
| 3 | Career in engineering; property bought 12 years ago; inheritance from a grandparent (declared). Agent found the purchase in the land registry (signed) and a probate record (signed) |
| 4 | Sale contract and solicitor's completion statement for 400,000 (verified with the solicitor) |
| 5 | One large deposit, then a single outgoing purchase payment; few other transactions |
| 6 | Parent holds a ministerial post; no business connection found between customer and parent's role |
| 8 | No adverse media on customer; parent subject of general political coverage only |
| 10 | Interview held; customer explained the purchase was funded partly by inheritance, matching probate dates |
| 11 | Analyst: source of wealth and funds supported by signed and verified documents |
| 12 | Approved by head of financial crime |
| 13 | Alert on any incoming funds from government-linked entities; review of outgoing purchase payment |
The agent's main contribution was item 3: it found the land registry purchase and the probate record, which turned a declared story into a documented one. The approver relied on those records, not on the customer's word.
Where Pryme fits
In Pryme, an EDD agent works at depth 1 and 2. Every fact is stamped with its provenance class, so an approver can see which parts of the file are the customer's account and which are verified. Approval is held for a named senior manager. See FATF customer due diligence with AI agents and AI compliance agents: second line, never the last word.
Questions people ask
Can the agent interview the customer?
It can collect written answers to set questions. A live interview on gaps or contradictions should be done by a person, because judging the answer is part of the point.
What if source of wealth cannot be evidenced?
Record what was found and what was not. A person decides whether to proceed, apply restrictions, or decline. The agent should never mark an unevidenced item as satisfied.
Does EDD need to be repeated at each review?
The relevant parts do: expected versus actual activity, screening and adverse media, and any change in PEP status. Source of wealth rarely changes but should be revisited if activity suggests it has.