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Home » Anti-Money Laundering » Basic Counterparty 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.
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.
It matches the real risk of the relationship. When risk factors appear, the case escalates to enhanced due diligence.
Every data point with its source and date. “If it isn’t documented, it never happened” is the rule every auditor applies.
It’s reviewed periodically and whenever something material changes with the counterparty.
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.
Who the person or entity is, checked against independent, reliable sources. Receiving the data isn’t enough: it has to be verified.
The individuals who own or control a legal entity.
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.
Watch the relationship to detect unusual transactions and keep customer information up to date.
We hear them from fintechs, insurers, family offices and professional firms with international clients alike.
The rule says “based on risk,” but no one gives you the criteria for deciding where each counterparty falls.
You can’t compare two counterparties, and no third party can review the work without starting from scratch.
A report that makes claims without citing sources won’t hold up with an auditor: you can’t defend what you can’t trace.
Documents are requested without a fixed checklist, and the file stays open for months waiting on the last piece.
Without an expected activity profile, every transaction looks normal, or they all look suspicious.
The file gets archived and no one looks at it again until there’s a problem.
Each problem above is matched by a specific part of the deliverable.
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.
The same sections in the same order. Two reports can be compared at a glance, and any reviewer knows where to look.
Record searched, date searched and what was found. Anything that couldn’t be verified is flagged as a gap, not glossed over.
We tell you exactly what to request from the counterparty and what we obtain ourselves, so you avoid three rounds of emails.
We define what is normal for this specific relationship. That becomes the benchmark for spotting anything unusual later on.
The report ends by telling you when to look at it again and which changes should trigger an early review.
This is the actual table of contents. If a section couldn’t be completed, it still appears, with an explanation of why.
Of the person, company, client or vendor, including the source of funds and source of wealth where applicable.
The individuals behind the entity, with the ownership chain traced and each link backed by a record.
Expected activity, markets, usual counterparties and how it operates. This is what turns a stray data point into a meaningful signal.
The level assigned and the specific factors behind it: jurisdiction, industry, structure, use of cash and product type.
Presence in court records, administrative records and relevant press coverage, with a clear line between proven fact and allegation.
The supporting file with sources and dates. If it isn’t documented, it never happened.
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.
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.
We tell you what to request from the counterparty and what we pull ourselves from public records. All in one round.
We check business registries, court records and reliable open sources, noting each source and date.
We trace the ownership chain and define the expected activity of the relationship.
We assign the risk level and explain, one by one, the factors that support it.
A report with findings, disclosed gaps and a recommendation on when to review it.
The work is led by Zulma Eliana Bourelly, a Certified Anti-Money Laundering Specialist (CAMS), with a team trained in anti-money laundering.
175 SW 7th Street, Suite 1905, in the financial district. A verifiable physical address.
Reports written so your management understands them and your regulator recognizes the technical terms.
The entire process is handled through documents and video calls.
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.
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
The general know-your-customer procedure and its components.
Sanctions, PEPs, source of funds and know your employee.
Existence, good standing, ownership and litigation of a US company.
A document search for marriages and divorces in public records.