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Enhanced Due Diligence (EDD) for Higher-Risk Clients

Standard client due diligence is about confirming identity; enhanced due diligence is about testing integrity. This course shows fee earners, partners and compliance teams how to move from basic verification to a structured, investigative approach whenever higher-risk features appear. Using realistic scenarios, learners see when EDD is legally required, what extra evidence is needed, and how to build a file that can withstand regulatory scrutiny.

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Identifies and addresses knowledge gaps

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Course Overview

Standard client due diligence is about confirming identity; enhanced due diligence is about testing integrity. This course shows fee earners, partners and compliance teams how to move from basic verification to a structured, investigative approach whenever higher-risk features appear. Using realistic scenarios, learners see when EDD is legally required, what extra evidence is needed, and how to build a file that can withstand regulatory scrutiny.

Who Should Take This Course

Partners, senior lawyers and fee earners who act for higher-risk or cross-border clients

MLROs, compliance and risk teams responsible for EDD policy and sign-off

Supervisors and heads of department who approve high-risk work or PEP relationships

Onboarding and intake teams who spot EDD triggers at the point of first instruction

What You'll Learn

  • The purpose of EDD and how it differs from standard CDD: from “who are you” to “is this wealth consistent with a lawful background”
  • A client-intake scenario involving Viktor Drago: PEP family connection, offshore BVI structure and a large investment fund
  • How to analyse EDD issues in Viktor’s case: PEP status, source-of-wealth evidence and justification for offshore structures
  • Mandatory EDD “red-zone” triggers under law and firm policy: PEPs and their relatives, high-risk jurisdictions, unusual/opaque structures and artificial urgency
  • The three pillars of an EDD investigation:
  • Pillar A – Source of funds and source of wealth, and the need for independent, proportionate evidence
  • Pillar B – Senior management approval and what genuine high-risk sign-off should look like
  • Pillar C – Enhanced ongoing monitoring, including re-screening and closer review of payments and structural changes
  • An “in-flight” scenario where a long-standing client suddenly changes the payment route to a Luxembourg vehicle, and how this becomes an EDD trigger mid-matter
  • How to treat new parties, jurisdictions or payment routes as fresh risk events requiring reassessment
  • What a robust “defence file” for EDD looks like: risk summary, evidence trail, reasoning and formal approval
  • When EDD should lead to a decision not to act, and how to communicate that decision without tipping off

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Key Learning Outcomes

By the end of this course, you will be able to:

  1. Explain when EDD is legally and procedurally required, and why it is not a discretionary extra.
  1. Identify key EDD triggers, including PEP connections, high-risk jurisdictions, opaque structures and artificial urgency.
  1. Plan and carry out EDD enquiries that properly evidence both source of funds and source of wealth.
  1. Prepare concise risk summaries and EDD packs that enable informed senior management approval.
  1. Apply enhanced ongoing monitoring to high-risk clients and matters, including responding to “in-flight” changes in payment routes or structures.
  2. Build a clear EDD “defence file” demonstrating what risks were identified, what was done to address them, and why the firm decided to proceed or decline.‍
  3. Support and, where necessary, recommend a decision to walk away from business where EDD concerns cannot be resolved, while avoiding tipping off.

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Why This Course Matters

Higher-risk clients and complex structures often bring attractive fee opportunities but also the greatest exposure if something goes wrong. Regulators expect firms to show not only that they identified risk, but that they investigated it properly and documented robust decisions. This course equips your teams to handle EDD with confidence—probing deeply but proportionately, collaborating effectively with compliance, and knowing when the safest commercial and professional decision is to say “no”.

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What people say

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Course materials can be accessed through our platform dashboard once you or your learners have been enrolled. Each learner will receive a Welcome Email with full instructions.

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You may cancel your course booking at any time before payment has been made by emailing us at hello@denkenknowledge.com. Once you have accessed your course on our platform no refunds will be made.

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