Higher-review workflows
Enhanced CDD involves additional, risk-targeted measures. It is not a universal document list, and the controls used should be proportionate, effective and appropriate to the risk and circumstances.
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General editorial information. Onboard is a domain portfolio and does not provide AML/CTF software or advice.
AUSTRAC identifies specific circumstances in which enhanced CDD applies, including high customer ML/TF risk and other defined situations. This guide does not reproduce a definitive trigger list; teams should use the current official guidance and their policies.
Additional information or verification should respond to the reason for enhanced review. Complex ownership, a change in risk, unusual activity or a relevant PEP context can require different investigation and evidence.
Technology may support case assignment, evidence requests, screening results, internal notes, approvals and an audit trail. It should also make unresolved issues visible and prevent a superficial “complete” status.
Enhanced measures may be relevant during initial CDD, ongoing CDD or both. Workflow configuration should support review over time where the risk and the reporting entity’s obligations require it.
Illustrative workflow
Illustrative workflow only — not a compliance template. The required process depends on the reporting entity, designated service, customer and risk.
Identify the circumstance and customer risk driving enhanced review.
Apply controls that address the specific risk rather than a generic bundle.
Collect, verify and assess the additional information needed.
Route the case under the reporting entity’s policies and responsibilities.
Preserve evidence and any ongoing control or monitoring decision.
Questions
Regulatory statements are linked to current AUSTRAC guidance. Provider facts on the market page link to each provider’s official website.