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Compliance and anti-money laundering

Basic Due Diligence

The standard level of counterparty verification, used when risk is normal and nothing calls for going further. A documented report, with sources cited and a reasoned risk rating.

Definition

What is basic due diligence?

Basic due diligence is the standard level of verification applied to a counterparty whose risk profile is normal: identify who they are, verify it against independent sources, understand why the relationship is being established and monitor it for as long as it lasts.

“Basic” doesn’t mean superficial. It means proportionate. The risk-based approach of FATF Recommendation 1 starts from a simple idea: the depth of the analysis is scaled to the risk, because treating everything at the highest level is as ineffective as treating everything at the lowest.

Whether you need due diligence, and how deep it should go, depends on the level of risk you or your company are willing to take on. This report is the foundation for that decision.

Proportionate, not minimal

It matches the real risk of the relationship. When risk factors appear, the case escalates to enhanced due diligence.

Documented from the start

Every data point with its source and date. “If it isn’t documented, it never happened” is the rule every auditor applies.

Kept current for the life of the relationship

It’s reviewed periodically and whenever something material changes with the counterparty.

The standard, broken down

The four requirements of the FinCEN rule

The Customer Due Diligence Final Rule (31 CFR 1010.230) doesn’t ask for a document: it asks for four things. A report that leaves out any of them is incomplete, no matter how many pages it has.

01

Identify and verify the customer

Who the person or entity is, checked against independent, reliable sources. Receiving the data isn’t enough: it has to be verified.

02

Identify and verify the beneficial owner

The individuals who own or control a legal entity.

03

Understand the purpose of the relationship

Why the relationship exists and what activity to expect. That builds the profile, and the profile is what lets you spot anything that doesn’t fit.

04

Monitor on an ongoing basis

Watch the relationship to detect unusual transactions and keep customer information up to date.

What clients tell us

Six problems for whoever has to sign off on the report

We hear them from fintechs, insurers, family offices and professional firms with international clients alike.

“I don’t know what level this client needs”

The rule says “based on risk,” but no one gives you the criteria for deciding where each counterparty falls.

“Every report I get comes in a different format”

You can’t compare two counterparties, and no third party can review the work without starting from scratch.

“They give me conclusions without telling me where they come from”

A report that makes claims without citing sources won’t hold up with an auditor: you can’t defend what you can’t trace.

“The client sends me documents a few at a time”

Documents are requested without a fixed checklist, and the file stays open for months waiting on the last piece.

“I can’t tell an odd data point from a red flag”

Without an expected activity profile, every transaction looks normal, or they all look suspicious.

“By the time I finish it, it’s already out of date”

The file gets archived and no one looks at it again until there’s a problem.

Problem by problem

How we solve it for you

Each problem above is matched by a specific part of the deliverable.

We give you the criteria, not just the result

The report explains why this counterparty falls into low, medium or high risk, with the factors that determine it. You can reuse the criteria on the next case.

One fixed format for every counterparty

The same sections in the same order. Two reports can be compared at a glance, and any reviewer knows where to look.

Every statement with its source and date

Record searched, date searched and what was found. Anything that couldn’t be verified is flagged as a gap, not glossed over.

A fixed document checklist from day one

We tell you exactly what to request from the counterparty and what we obtain ourselves, so you avoid three rounds of emails.

Expected activity profile

We define what is normal for this specific relationship. That becomes the benchmark for spotting anything unusual later on.

Recommended review schedule

The report ends by telling you when to look at it again and which changes should trigger an early review.

The deliverable

What the report contains, section by section

This is the actual table of contents. If a section couldn’t be completed, it still appears, with an explanation of why.

Full identification

Of the person, company, client or vendor, including the source of funds and source of wealth where applicable.

Ownership and control

The individuals behind the entity, with the ownership chain traced and each link backed by a record.

Counterparty profile

Expected activity, markets, usual counterparties and how it operates. This is what turns a stray data point into a meaningful signal.

Risk rating

The level assigned and the specific factors behind it: jurisdiction, industry, structure, use of cash and product type.

Public background

Presence in court records, administrative records and relevant press coverage, with a clear line between proven fact and allegation.

Documentation and traceability

The supporting file with sources and dates. If it isn’t documented, it never happened.

The limit of this level

When a case stops being basic

In some circumstances the risk is higher and the international standard requires enhanced measures. If any of these factors comes up during the work, we tell you and propose escalating the case before going further.

Escalating doesn’t mean starting over.

All the basic-level work is kept and serves as the foundation. Enhanced due diligence adds layers (sanctions, PEPs, close associates, source of funds, know your employee) on top of a file that is already built.

That is why it makes sense to start here even when you suspect the case will end up as enhanced: the groundwork is done once and never has to be redone.

Step by step

How we do it

01

Scoping the case

Which counterparty, in which jurisdictions and for what decision. This tells us whether the case stays at the basic level or must escalate from the start.

02

A fixed document checklist

We tell you what to request from the counterparty and what we pull ourselves from public records. All in one round.

03

Document verification

We check business registries, court records and reliable open sources, noting each source and date.

04

Ownership and profile

We trace the ownership chain and define the expected activity of the relationship.

05

Risk rating

We assign the risk level and explain, one by one, the factors that support it.

06

Delivery and review schedule

A report with findings, disclosed gaps and a recommendation on when to review it.

Why work with us

What sets us apart

Led by a CAMS-certified specialist (ACAMS)

The work is led by Zulma Eliana Bourelly, a Certified Anti-Money Laundering Specialist (CAMS), with a team trained in anti-money laundering.

Our own office in Brickell, Miami

175 SW 7th Street, Suite 1905, in the financial district. A verifiable physical address.

Reports in English or Spanish

Reports written so your management understands them and your regulator recognizes the technical terms.

No need to travel to the United States

The entire process is handled through documents and video calls.

Frequently asked questions

What clients ask about the basic level

It is the standard level of counterparty verification: identifying the counterparty, verifying it against independent sources, understanding the purpose of the business relationship and monitoring it for as long as it lasts. It applies when the risk profile is normal and no factors call for enhanced measures.

In depth and scope. Basic due diligence establishes who the counterparty is and what to expect from the relationship. Enhanced due diligence adds systematic sanctions list screening, analysis of politically exposed persons and their close associates, source of funds and, where applicable, know your employee. Enhanced builds on basic: it doesn’t replace it.

When the counterparty operates in a jurisdiction with a recognized AML framework, its ownership structure is transparent, its industry is not high risk and there are no matches on restricted-party lists. If any of those conditions isn’t met, the case escalates.

The CDD Final Rule (31 CFR 1010.230) requires identifying and verifying the customer, identifying and verifying its beneficial owner, understanding the nature and purpose of the relationship to build a risk profile, and conducting ongoing monitoring to detect unusual transactions and keep information up to date.

Yes, and the reasoning too. We don’t just hand you a “medium risk” label: we give you the specific factors behind it (jurisdiction, industry, structure, use of cash, product type) so you can defend the decision and reuse the criteria.

It’s reported as a gap, with an explanation of why: a record without public access, an opaque jurisdiction or documentation that doesn’t exist. An honest report about what couldn’t be confirmed is worth more than one that fills the blanks with assumptions.

Ongoing monitoring is part of the standard itself. The review schedule is scaled to the assigned risk level, and any relevant change (ownership structure, country of operation, type of activity) calls for an early review.

For both. For legal entities, the work includes tracing the ownership chain down to the individuals behind it; for individuals, the focus is on identity verification, public background and source of wealth.

Yes. Risk comes in through both doors. Verifying vendors, distributors and business partners follows the same procedure as verifying clients.

No. We carry out the documentary procedure and give you findings, a rating and the reasoning behind it. The acceptance decision belongs to your company under its own policy. We also don’t issue legal opinions: that is for a licensed attorney.

It depends on the number of jurisdictions and how deep the corporate structure goes. We give you a specific timeline in writing before we start, and we let you know if something comes up during the work that requires escalating the case.

Yes. It is handled with restricted access, used only for the engagement and not shared with third parties.

Need a counterparty verified?

Tell us who you need to verify and for what decision. We’ll tell you whether the basic level is enough or your case calls for enhanced measures, and what the report would contain.

or call us at +1 (305) 647-3000 · Monday through Friday
175 SW 7th St, Suite 1905 · Miami, Florida 33130

Keep exploring

Other services in our compliance line

KYC — Know Your Customer

The general know-your-customer procedure and its components.

Enhanced Due Diligence

Sanctions, PEPs, source of funds and know your employee.

US company verification

Existence, good standing, ownership and litigation of a US company.

Marital status search

A document search for marriages and divorces in public records.