Customer Due Diligence: Onboarding & Ongoing Monitoring

Customer due diligence (CDD) is a core requirement under Kenya’s AML framework. It is not a one-off form at onboarding, it is a continuous process of knowing who your customers are and whether their activity makes sense.

At onboarding

Before you establish a relationship, you must identify and verify the customer, understand the purpose and intended nature of the relationship, and assess the risk they present. For companies and trusts, that includes identifying the beneficial owners, the real people behind the entity.

Enhanced due diligence

Higher-risk customers require more. Enhanced due diligence (EDD) applies to politically exposed persons (PEPs), customers in high-risk sectors or geographies, and unusual ownership structures. EDD typically means establishing source of funds and wealth, obtaining senior sign-off, and monitoring the relationship more closely.

Ongoing monitoring

CDD does not end at onboarding. You must monitor transactions to ensure they are consistent with what you know about the customer, and keep customer information up to date. Screening against sanctions and PEP lists should be ongoing, not just at the start.

Triggers for review

Certain events should prompt a fresh look: a significant change in transaction behaviour, a change in ownership, a sanctions hit, or the customer moving into a higher-risk category. A practical, risk-based CDD process makes these reviews routine rather than reactive.