Sanctions Evasion Reference

Enhanced due diligence

Additional scrutiny applied where risk is assessed as higher, including deeper enquiry into source of funds, ownership and the purpose of specific transactions.

also known as

EDD

reviewed

2026-08-20

Enhanced measures are what a risk-based system does instead of treating every customer identically. They typically involve obtaining more information about ownership and source of wealth, senior approval for the relationship, and closer ongoing monitoring.

In sanctions work the trigger is usually a combination rather than a single fact: a jurisdiction, plus an unusual structure, plus a commodity, plus a payment route that none of the three explains.

Where this term is used

  • What is dual-use re-export diversion? — Buying controlled civil-use goods lawfully in an open market and re-exporting them to a restricted end user, exploiting the fact that the item itself looks entirely ordinary.
  • How is correspondent banking used to evade sanctions? — Using a chain of banks that each know only their own customer, so that a payment for a restricted party reaches a currency it could not access directly, without any bank in the chain seeing the whole transaction.
  • What is a professional enabler? — A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.

Related terms

  • Customer due diligence — The ongoing process of understanding a customer's identity, ownership, expected activity and risk, and checking that actual activity remains consistent with it.
  • Red-flag indicator — A published, attributable observation that a transaction or relationship warrants further enquiry, drawn from patterns seen in past cases.
  • Screening — Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.

Sources

  1. The FATF Recommendations. Financial Action Task Force, 2025.
  2. Correspondent banking principles and guidance. The Wolfsberg Group, 2022.

All glossary terms