Services / Enhanced Due Diligence
Enhanced due diligence
Know exactly who you are dealing with before the money moves
When a customer, counterparty or investor is high risk, a database search is not enough. Valitros runs the full enhanced due diligence file: who they really are, where the wealth came from, who stands behind the company, and whether what they told you checks out on the ground.
Australian AML/CTF law requires enhanced customer due diligence when the risk is high: politically exposed persons, high risk jurisdictions, complex or opaque ownership, unusual source of funds, or anything that does not add up. The same expectation exists under the UK Money Laundering Regulations and the EU directives.
Most firms can screen a name. Very few can answer the questions that actually decide the matter: is the wealth story true, does the business exist at the address, who controls the trust behind the holding company, and what do people in that market know about this person that never made it into a database.
That is the gap Valitros fills. We combine the screening tools you already have with human research and physical verification in the countries where the answers are, and we give you a report your compliance officer, board or lawyer can act on.
What you get
Identity and reputation
Confirmation of who the person is, what they have done, litigation and insolvency history, regulatory actions, licences, directorships past and present, and adverse media in local languages, not only English.
Source of wealth and source of funds
A documented account of how the wealth was built and where the specific funds for this transaction come from, with the evidence tested rather than accepted: company accounts, property records, sale contracts, employment and business history.
Beneficial ownership and control
The real people behind companies, trusts, foundations and nominee arrangements, traced through registries in each jurisdiction and reconciled against what you were told.
PEP, sanctions and state links
Political exposure including family and close associates, sanctions and watchlist matches resolved to a yes or no rather than a list of possibles, and links to state owned or state influenced entities.
On the ground verification
Site visits to registered offices, factories, warehouses and homes where a visit is lawful and proportionate; discreet local reputation enquiries with people willing to speak; confirmation that the operation described actually exists at the scale claimed.
A report you can rely on
Findings separated from opinion, every fact sourced, gaps stated plainly, and a clear risk assessment with recommended conditions. Written so it can be attached to your AML file, tabled at a board, or handed to your lawyers.
How it works
Step 1
Scope in one call
Tell us who, where, what decision the report supports and when you need it. We come back within one business day with a written scope, the jurisdictions involved, a fixed fee or a capped estimate, and a delivery date.
Step 2
Desk phase
Registries, courts, regulators, licensed databases, media in local languages and open sources across every relevant jurisdiction. Most matters have a preliminary read within three to five business days.
Step 3
Field phase
Where the scope calls for it, vetted local partners verify premises, confirm operations and make lawful reputation enquiries. You are told who is instructed and what they will and will not do before they start.
Step 4
Report and briefing
A written report with a one page summary, a findings section with sources, and a risk assessment. We walk you through it on a call and answer the follow up questions that always come.
Where we work
Core markets for on the ground work. Desk research covers every jurisdiction.
South East Asia
Singapore, Vietnam, Thailand, Philippines, Indonesia, Malaysia
Europe
United Kingdom, Ireland, Germany, Netherlands, France, Spain, Poland, Switzerland, Cyprus, Malta
Middle East
United Arab Emirates, Saudi Arabia, Qatar, Bahrain, Oman, Kuwait, Turkey
Africa
South Africa, Kenya, Nigeria, Ghana, Egypt, Morocco, Mauritius
Lawful, and clear about it
- Valitros is not a law firm and does not give legal advice. Where a matter needs legal advice, privilege or court process, we work under the direction of your lawyers.
- Investigative fieldwork is carried out by our team and by vetted local partners who hold the licences their jurisdiction requires. We do not name partners publicly, and we tell you who is instructed on your matter before they start.
- Every method we use is lawful: public and official records, licensed databases, open source research, consented reference and document checks, interviews with people who agree to speak, and physical verification of premises from public places. We do not pretext, access private systems or accounts, intercept communications, or conduct surveillance that breaches privacy or harassment laws.
- Personal information is collected and handled under the Australian Privacy Act and the Australian Privacy Principles, and under the GDPR and local data protection law where the subject or the work is in those jurisdictions.
Questions we are asked
When is enhanced due diligence required?
Under the Australian AML/CTF Act and Rules, when your risk assessment rates a customer as high risk, and always for foreign politically exposed persons, correspondent banking relationships and customers linked to high risk jurisdictions. UK and EU regimes have equivalent triggers. Beyond the legal minimum, most firms apply it whenever the amount, the structure or the story warrants a second look.
How long does it take?
A desk based enhanced due diligence report on an individual or a single company usually takes five to ten business days. Multi jurisdiction files with fieldwork take two to four weeks. Urgent preliminary findings can be delivered in 48 hours where the decision cannot wait.
Can you check people and companies in countries where records are poor?
Yes. That is precisely where on the ground work matters most. Where registries are incomplete or unreliable, we rely on physical verification, licensed local partners, court and regulator records that are not online, and lawful reputation enquiries, and we tell you clearly how confident each finding is.
Is the report usable in an AUSTRAC audit or a court?
The report is written to be attached to your AML/CTF records as the evidence behind your risk rating and your senior manager decision. For litigation, we work under your lawyers so that privilege is preserved and the evidence is gathered in a way that can be relied on.
What do you not do?
We do not access private accounts or systems, intercept communications, use pretexts to obtain information from banks or government, or conduct covert surveillance that breaches privacy or harassment laws. If the only way to get an answer is unlawful, we tell you it cannot be obtained.
Guides
Enhanced due diligence on a high risk customer: the checklist compliance officers actually use
What enhanced customer due diligence has to cover under Australian and UK AML rules, how much evidence is enough, and where firms get caught out.
7 minute read
Source of wealth verification: how to test the story instead of filing it
A practical method for verifying source of wealth and source of funds on high value or high risk customers, with the documents that count and the red flags that should stop a matter.
6 minute read
Finding the real owner: beneficial ownership through trusts, nominees and offshore companies
How to trace beneficial ownership when the customer sits behind layered companies, trusts and nominee shareholders across several jurisdictions, and what to do when the registry runs out.
7 minute read
On the ground verification: why a site visit changes the answer
What a lawful site visit and local reputation enquiry can establish that no database can, when it is proportionate, and how it is done without breaking the law or tipping anyone off.
6 minute read
Talk it through
A thirty minute call to understand the matter, the countries involved and the decision it has to support. Written scope and fee within one business day.
Book a scoping call