Readers have asked me to relate the enhanced due diligence techniques that I employed in last week's chapter (Confessions of a Money launderer - part 70, dated 15 September, 2008), and this might also be a good time to also review the topic in detail. When several compliance officers get together to talk shop, and the subject of what is appropriate and necessary for the proper enhanced due diligence investigation in a customer identification programme comes up, there is generally a marked disagreement as to what one must do. If in doubt, follow this maxim: just when you think you have done all that you should, press on and continue, until you have either satisfied yourself as to the bona fides of the target, or you have found him to be an unacceptable risk. It's one or the other, and to do any less is simply not enhanced due diligence, in my humble opinion. Remember, I have been there, and know what you have to deal with every day: anxious relationship managers who want you to quickly and amiably approve all their new clients, ambitious senor staff who want to bring in that high net-worth businesses, that pile of unfinished files, already sitting on on your desk. That's why I used to be at my desk at 7am every morning; so that I could complete my unfinished work before the New Accounts staff came by during normal business hours to bother me with their pending CIP complaints.

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