Duration 2 days – 14 hrs
Overview
This hands-on course helps participants apply Customer Due Diligence (CDD) correctly in real operations using a risk-based approach. It focuses on practical customer risk profiling, deciding when RDD (Reduced), ADD (Additional), or EDD (Enhanced) due diligence is appropriate, and documenting decisions in a way that stands up to QA, audit, and regulatory review. Participants also learn how to handle transactors / non-account customers (walk-ins, OTC, remittance, cash-in/out, one-time transactions) under risk-based CDD and monitoring.
Objectives
- Explain and apply the risk-based approach to CDD across onboarding, servicing, and transactions.
- Perform customer risk profiling using standard risk factors (customer type, geography, product/service, channel, behavior).
- Distinguish RDD vs ADD vs EDD and apply the correct level based on defined triggers.
- Identify common EDD triggers (e.g., high-risk customer types, PEP indicators, unusual patterns, high-risk geographies/channels, complex ownership structures, adverse information).
- Execute CDD/EDD documentation: what evidence is needed, how to write a defensible rationale, and how to record approvals/exceptions.
- Handle transactors/non-account customers with appropriate identification, threshold-based checks (where applicable), escalation, and record-keeping.
- Reduce rework by applying quality standards for completeness, consistency, and audit trail.
Audience
- KYC analysts / onboarding teams / account maintenance
- Branch/ops staff handling customer updates and transactions
- Customer support teams supporting onboarding or verification
- Compliance / QA reviewers who validate KYC files
- Team leads/supervisors for KYC operations
Pre- requisites
- Basic understanding of AML/KYC concepts (or completion of AML/CTF Fundamentals)
- Familiarity with your organization’s onboarding/transaction processes is helpful (not required)
Course Content
Day 1 — Risk-based CDD foundations and profiling
Module 1: Risk-Based CDD essentials
- What “risk-based” means in day-to-day operations
- CDD lifecycle: onboarding → ongoing monitoring → periodic review → event-driven review
- Roles and handoffs (frontline, ops, compliance, QA)
Exercise: CDD lifecycle mapping for your process
Module 2: Customer risk profiling workshop
- Risk factors and how to score/weight them:
- Customer type (individual, corporate, NGO, etc.)
- Product/service risk
- Delivery channel risk (digital/agent/branch)
- Geography risk
- Behavior risk
- Risk rating outcomes and what it changes (CDD depth, approvals, review frequency)
Workshop: Risk-rate 5 customer profiles + justify the rating
Module 3: RDD vs ADD vs EDD decisioning
- Clear definitions and operating rules
- What typically qualifies for:
- RDD: lower-risk profile + stable patterns + clean signals
- ADD: gaps needing additional info before proceeding
- EDD: higher inherent risk or high-risk triggers
- Building a decision tree your team can follow
Deliverable: RDD/ADD/EDD decision matrix template
Module 4: EDD triggers deep dive
- Common EDD triggers and how to evidence each one:
- High-risk customer type / industry
- PEP indicators (and PEP-related risk handling)
- Unusual behavior vs stated profile
- Complex/opaque ownership structure
- High-risk geography / corridor / channel
- Negative news/adverse info signals
- Escalation rules and approvals
Exercise: “Trigger or not?” scenario drill
Day 2 — Documentation mastery and transactors/non-account customers
Module 5: Documentation that survives QA/Audit (
- What “defensible” documentation looks like:
- Evidence checklist (IDs, business docs, BO, source of funds/wealth as applicable)
- Consistency checks (names, addresses, nature of business, purpose)
- Capturing rationale: why this risk rating and why this CDD level
- Handling exceptions: expired IDs, missing docs, alternative evidence, temporary controls
- Common findings and how to prevent them
Workshop: Fix a “bad KYC file” and rewrite the rationale
Module 6: Beneficial Ownership basics (for CDD practice)
- Identifying BO and control persons (practical approach)
- Ownership structure red flags (layering, nominees, shell entities)
- Documentation pack and verification steps
Workshop: BO identification from 2 sample org charts
Module 7: Transactors / Non-account customers
- Who are transactors and why they matter
- Practical handling model:
- Identification and minimum data capture
- Threshold-based and risk-based checks (where applicable)
- When to escalate / refuse / delay / request more info
- Record keeping and watchlist screening considerations
- Patterns: structuring/smurfing, mule behavior, rapid cash-in/cash-out
Scenario lab: Walk-in transactions and edge cases
Module 8: Operating controls and QA framework
- Maker-checker controls and approvals
- KYC QA scoring (completeness, accuracy, rationale, evidence)
- KPIs for KYC ops: rework rate, turnaround time, defect density
- Continuous improvement: top root causes and quick fixes
