Enhanced due diligence procedure: stages and deadlines
Enhanced due diligence starts when a standard check flags a risk factor: a high-risk jurisdiction, a politically exposed person, an unusual transaction pattern, or a source of funds that cannot be explained by ordinary documentation. From that point, the file moves onto a separate track with its own stages, its own document list, and its own decision points. The procedure typically runs from a few working days to several weeks, depending on how quickly the customer responds and how many jurisdictions are involved.
What triggers the enhanced track
A compliance officer or an automated screening layer marks a customer or a transaction as elevated risk. From that moment, the file is frozen at its current stage: no new product access, no increased transaction limits, no change of beneficial ownership, until the enhanced check closes. The trigger itself does not need to be dramatic. A mismatch between declared occupation and transaction volume is enough to move a file onto this track.
Practical consequence for the timeline
Once a file enters the enhanced track, the ordinary onboarding clock stops and a separate clock starts. The customer is asked for additional documents, and the file cannot close until every document is received, reviewed, and either accepted or escalated. If the screening tool that generated the original alert is provided by an external vendor and stalls after an update, the resulting delay is a vendor performance issue rather than a compliance one, and it is worth checking whether When an SLA credit regime is triggered before the internal deadline is treated as breached.
Stages, in order
| Stage | Typical duration | Output |
|---|---|---|
| Trigger and freeze | Same working day | File flagged, ordinary processing suspended |
| Additional information request | 1–3 working days to send | Written request to the customer, listing exact documents |
| Customer response window | 5–15 working days, set by internal policy | Documents received or non-response recorded |
| Internal review | 3–10 working days | Analyst memo with a recommendation |
| Senior sign-off | 1–5 working days | Approval, rejection, or referral to the reporting officer |
| Closure or escalation | Same day as sign-off | File closed with a record, or referred onward |
What to do
- The compliance officer records the trigger and the exact reason for it, in writing, on the same day the alert appears.
- The relationship owner sends a single, complete request for additional documents rather than several partial ones.
- The customer is given a fixed response window, stated in calendar days, with the consequence of missing it stated in the same message.
- The analyst reviewing the response documents every gap between what was requested and what was received.
- Senior management signs off on the outcome before the file is closed or escalated; a single reviewer cannot close an enhanced file alone.
- The decision, and the reasoning behind it, is stored in a form that can be reproduced during a later inspection.
Who decides, and by when
The compliance officer owns the file throughout. Senior management, not the analyst who ran the check, approves closure of an enhanced file. Where the review reveals a genuine ownership dispute rather than a documentation gap, the file cannot be closed on ordinary compliance grounds. A held-up attestation is one example: where When a co-owner refuses to sign the required beneficial ownership confirmation, the enhanced file is paused and the ownership question is treated separately from the compliance question. Deadlines for each internal stage are set by policy, not by the customer; only the response window is communicated externally.
Forks: three situations, three routes
If the customer responds in full within the window, the file moves to internal review on schedule and closes on the ordinary track. If the customer responds partially, the missing items are requested once more, with a shorter second window, before escalation is considered. If the customer does not respond at all, the file is escalated to the reporting officer once the window lapses, and the underlying relationship is restricted pending that decision. A licensed entity facing a parallel supervisory question should treat the two tracks as separate: see A licence is suspended pending review authorisation who decides for how a supervisory freeze runs alongside an internal compliance file rather than replacing it.
Where this page stops
This page describes the procedural mechanics common to obliged entities handling enhanced checks. It does not set the exact response window your organisation must use, does not list which risk factors your internal policy treats as automatic triggers, and does not decide a specific file. Those depend on your written AML policy and on the facts of the case in front of you.
Verified
Reviewed by the author against current internal procedural practice for obliged entities. Stage names and typical durations reflect common compliance operating practice rather than a single named source; they are not a substitute for your organisation's own written procedure. Last checked: this page is reviewed on a recurring schedule; contact the practice for the current review date if it matters for your file.
Related
The enhanced track usually starts because a screening rule fired. If the alert itself looks wrong, the fix is upstream: Screening tuning step by step covers how those rules are adjusted without creating a new gap.
Get a first response today
If your file is stuck between stages and the deadline is close, write in and a partner responds during business hours, usually within minutes. For a separate but structurally similar procedural question outside AML, When a standard body claims your patent is essential walks through a comparable staged process with its own decision points.
FAQ
How long does enhanced due diligence procedure take in practice?
Most files close within two to six weeks. The single largest variable is how quickly the customer supplies a complete response; internal review and sign-off rarely take more than two weeks combined once the documents are in hand.
Which documents are needed to start?
The starting set is usually a source-of-funds explanation, identification for every beneficial owner above the applicable threshold, and, where relevant, evidence of the business relationship's commercial purpose. The exact list depends on why the file was flagged.
What happens if the other side does not respond?
Once the response window lapses without a reply, the file is escalated to the reporting officer and the relationship is restricted. A non-response is treated as a substantive outcome in its own right, not as a delay to be chased indefinitely.