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Customer Due Diligence (CDD)

2 min read
Pronunciation
[kuhs-tuh-mer doo dil-i-juhns]
Analogy
Think of Customer Due Diligence like a bank doing a thorough background check before opening a new account for someone. They'll ask for identification (like a driver's license or passport), verify that information, and try to understand the customer's financial activities to ensure they aren't planning to use the account for illegal purposes. It's about knowing your customer to keep the financial system clean.
Definition
Customer Due Diligence (CDD) is the process that financial institutions and other regulated businesses use to identify and verify the identity of their clients. It is a critical component of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) compliance efforts, aiming to prevent illicit financial activities by understanding who their customers are and the nature of their transactions.
Key Points Intro
CDD is a fundamental AML/CFT practice involving client identification, verification, and risk assessment.
Key Points

Client Identification & Verification: Collecting and confirming information about a customer's identity (e.g., name, address, DOB, ID documents).

Risk Assessment: Assessing the money laundering or terrorist financing risk posed by a customer.

Ongoing Monitoring: Continuously monitoring customer transactions and activity for suspicious behavior.

Regulatory Requirement: Mandated by AML/CFT laws and regulations globally for financial institutions and other designated businesses.

Example
A cryptocurrency exchange onboarding a new user performs CDD by: requiring the user to submit a government-issued ID and proof of address, using verification services to confirm the authenticity of these documents, screening the user against sanctions lists and Politically Exposed Persons (PEP) lists, and assigning a risk score based on their profile and intended activity. For higher-risk customers, Enhanced Due Diligence (EDD) might be applied.
Technical Deep Dive
CDD processes typically involve: 1. **Identifying the customer:** Collecting identifying information (name, address, date of birth, incorporation details for legal entities). 2. **Verifying the customer's identity:** Using reliable, independent source documents, data, or information (e.g., government IDs, utility bills, database checks, biometric verification). 3. **Identifying beneficial owners (UBOs):** For legal entities, determining who ultimately owns or controls the customer. 4. **Understanding the nature and purpose of the business relationship:** Assessing expected transaction types and volumes. 5. **Ongoing due diligence:** Monitoring transactions and updating customer information as needed. Enhanced Due Diligence (EDD) involves more intrusive measures for higher-risk customers. Simplified Due Diligence (SDD) may be applied for lower-risk scenarios.
Security Warning
Failure to conduct adequate CDD can expose institutions to significant regulatory fines, legal repercussions, and reputational damage if they are found to have facilitated illicit financial activities. Identity theft and synthetic identities pose challenges to CDD processes.
Caveat
CDD measures can introduce friction into the customer onboarding process. Balancing regulatory compliance with user experience is a key challenge. The effectiveness of CDD depends on the quality of data, verification tools, and internal processes. Global variations in CDD requirements add complexity for international businesses.

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