Complete third-party intelligence. In under five minutes.

Under FICA’s risk-based approach, Enhanced Due Diligence is triggered when a client relationship presents an elevated risk profile. Key triggers include: the client is identified as a Politically Exposed Person (PEP) or Prominent Influential Person (PIP), or closely associated with one; the client is connected to a high-risk jurisdiction or FATF grey-listed country; the transaction or business relationship involves an unusual or complex ownership structure without clear commercial rationale; the source of wealth or funds cannot be readily established through standard CDD; the business involves high-risk products or delivery channels; or an existing client’s circumstances change materially, raising their risk rating. EDD may also be warranted when account activity is inconsistent with the client’s known profile. KYCopilot’s EDD reports are structured to document your response to each trigger, with source-cited evidence and a risk rationale that satisfies RMCP requirements.

FICA’s risk-based approach creates three tiers of customer due diligence, each proportionate to the risk the relationship presents. Simplified CDD applies to clients and products assessed as genuinely low-risk — a reduced identification and verification process is permitted. Standard CDD applies to the majority of business relationships, requiring full identity verification, understanding of the nature and purpose of the relationship, and ongoing scrutiny commensurate with the risk level. Enhanced Due Diligence applies to high-risk relationships — including PEPs, PIPs, clients connected to high-risk or grey-listed jurisdictions, and complex or opaque corporate structures — requiring deeper investigation, source of wealth documentation, senior management approval in applicable cases, and more frequent review. KYCopilot operates at the EDD tier, generating comprehensive intelligence reports for the relationships that carry the highest regulatory scrutiny burden.

Your Risk Management and Compliance Programme must demonstrate not only that EDD was conducted, but that its substance was sufficient for the risk level identified. A FICA-compliant EDD record should include: verified identity details of the client and key controllers; screening outcomes across sanctions, PEP/PIP and adverse media databases with full source citations; a documented risk rationale explaining the risk rating and the basis for accepting or declining the relationship; source of wealth and source of funds evidence where applicable; a country risk assessment where geographic exposure is relevant; court and litigation record checks; and the identity of the person who reviewed and approved the assessment. KYCopilot’s reports address each of these elements in a single exportable document — including AI-generated narrative, match confidence ratings, source links and actionable compliance recommendations.

Section 28 of the FIC Act requires accountable institutions to retain all customer due diligence records — including EDD reports, identity verification documents and supporting evidence — for a minimum of five years from the date on which the business relationship ends, or from the date of a single transaction where no ongoing relationship exists. This retention obligation applies whether the relationship was ultimately established or declined following the EDD review. The FIC may request access to these records during an inspection, and failure to produce them constitutes a compliance breach independent of any substantive due diligence failure. KYCopilot EDD reports are fully exportable as structured documents, making it straightforward to archive them immediately against your Section 28 obligation from the day the report is generated.