What EDD involves

Where EDD applies, lawyers should expect additional scrutiny of the client, the matter and any associated funds.

Depending on the circumstances and the risks identified, EDD may include one or more of the following:

• obtaining additional information about the client, beneficial owners or controlling individuals;
• obtaining additional information about the purpose and intended nature of the matter;
• obtaining additional information about the source of funds;
• obtaining and assessing evidence relating to source of wealth;
• carrying out additional open-source or adverse media research;
• obtaining additional evidence to verify ownership, control or authority to instruct;
• obtaining senior management or MLRO approval before proceeding;
• imposing conditions on how funds may be received or transferred;
• increasing the frequency and intensity of ongoing monitoring; and
• requiring additional reviews before key stages of the matter proceed.

The precise measures required should be tailored to the risks identified.