By Andréas Hobbelin · 2026-10-12

When is an Enhanced Due Diligence good enough?

A risk-based view of EDD: when an automated report is proportionate, and when a senior investigator must be involved.

EDD is risk-based, not maximal

EU AML Directives and the FATF Recommendations require measures proportionate to the risk. More checks are not automatically better; the right checks, documented, are.

A good-enough EDD verifies identity and ownership, screens sanctions, PEP and adverse media, understands the purpose of the relationship and the source of funds, and records a reasoned conclusion.

When an automated EDD is proportionate

Transparent ownership, low-risk jurisdictions, no sanctions or PEP indicators, and a plausible, documented economic purpose. An automated, evidence-backed report is then usually sufficient.

When more must be done

Unresolved UBO, nominee or layered structures, confirmed or possible sanctions matches, PEP exposure, high-risk corridors, unexplained wealth, or adverse media that may still be relevant. Here an expert review is needed to interpret, verify and conclude.

How EDD Solution handles it

The engine flags these triggers deterministically and never lowers mandatory floors. When they appear, the report recommends the expert-reviewed tier, where Andréas Hobbelin reviews and confirms the findings.