AML / CTF
A risk-based framework. Connected controls.
FIDERE’s risk-based framework for client due diligence, beneficial ownership verification, transaction monitoring and escalation.
- 01
Understand the client
Client due diligence establishes the identity and context of the proposed relationship. Beneficial ownership verification helps identify the people who ultimately own or control an arrangement.
- 02
Consider the risk
The client, ownership structure and proposed activity inform the assessment. Higher-risk circumstances may require enhanced due diligence and further corroboration.
- 03
Monitor the activity
Transaction monitoring and continuing review consider activity within the established client context. A change in behaviour or an unusual pattern may require closer examination.
- 04
Review and escalate
Potentially suspicious activity is subject to review and escalation. The controls themselves are reviewed periodically against legal, regulatory and operational risk requirements.
When a closer review is required.
High-risk jurisdictions, opaque ownership chains, unusual transaction patterns or a mismatch between stated and observed activity may lead to further checks. These may include independent corroboration of source of wealth, management approval or tighter transaction controls.
This topic explains part of FIDERE’s published Compliance & KYC policy, effective 1 April 2026. The full policy contains the operative wording.
Read the complete policy