Enhanced due diligence is the deeper review a firm runs on a high-risk relationship. MLR 2017 reg 33 lists when it is compulsory, from a high-risk third country to a complex or unusually large transaction with no clear purpose. Reg 34 adds the extra measures for a customer established in such a country. anonym.plus removes names, identifiers, and wealth data from the dossier on your device.
When this applies
Source of wealth is the heart of the file. It is also what an unexplained wealth order under POCA 2002 s.362A puts to a respondent. Your own risk assessment under MLR 2017 reg 18 decides how deep the review goes. A committee asked for a fresh view needs the rationale, not the person.
How anonym.plus handles it
- Open the dossier in anonym.plus on your device.
- Local OCR reads scanned wealth documents.
- The tool flags names, identifiers, and account data.
- Keep the risk rationale and rating.
- Swap each identifier for a label.
- Save the clean dossier locally.
What you need to provide
- The EDD dossier (PDF, DOCX, or scan).
- An operator (Replace keeps the rationale readable).
- Optional name map for repeat subjects.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Yara Cole → [SUBJECT] |
| Identifiers | UK_PASSPORT | passport 9930 → [PASSPORT] |
| Financial | IBAN_CODE | GB60 HBUK 4012 → [IBAN] |
| Money | MONEY | £2.1M wealth → [AMOUNT] |
| Dates | DATE_TIME | DOB 1972 → [DOB] |
| Location | LOCATION | Edinburgh, UK → [LOCATION] |
Compliance achieved
- MLR 2017 reg 33 lists when enhanced due diligence is compulsory.
- MLR 2017 reg 34 adds the measures for a customer in a high-risk third country.
- Source-of-wealth reasoning is what an unexplained wealth order under POCA 2002 s.362A tests.
- How deep the review goes follows the firm's risk assessment under MLR 2017 reg 18.
- MLR 2017 reg 40 keeps the full record for five years.
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Limitations & cautions
The firm must retain the full EDD record for the reg 40 period. Share only a cleaned copy. A rare wealth figure tied to one region can re-identify a subject, so review what stays before you circulate it.
Frequently asked questions
Can EDD redaction replace the retained file?
No. Reg 40 keeps the full record for five years. Redaction makes a safe copy for committee or external review.
When is enhanced due diligence compulsory?
Reg 33 lists the triggers. They include a high-risk third country, a politically exposed person, a correspondent relationship, and a complex or unusually large transaction with no clear economic purpose.
Is source-of-wealth detail flagged?
Yes. Wealth figures and account data are flagged beside the subject's name, while the rationale for the rating stays readable.