Blog

Notes and analysis from the research team.

Shorter pieces on evidence, judgment and the work that sits around an intelligence file.

9 resources
The FCA’s Latest CDD Review Sends a Clear Message: Due Diligence Must Be Evidenced, Not Just Performed

The FCA’s Latest CDD Review Sends a Clear Message: Due Diligence Must Be Evidenced, Not Just Performed

The FCA’s 2026 review of customer due diligence controls highlights a recurring weakness across firms: due diligence may be taking place, but firms cannot always demonstrate what was done, why it was done, or how higher-risk customers were treated differently. The findings reinforce the need for structured, risk-based and evidence-backed CDD and EDD processes.
FCACustomer Due DiligenceCDDEnhanced Due Diligence
Source of Wealth Due Diligence in Singapore: Why the Focus Is Shifting From More Information to Better Information

Source of Wealth Due Diligence in Singapore: Why the Focus Is Shifting From More Information to Better Information

Singapore’s Source of Wealth guidance is moving toward a more risk-proportionate approach, focusing on material wealth drivers, relevant evidence, and plausibility rather than exhaustive document collection. This creates a strong role for technology-assisted public-source research to help financial institutions investigate wealth faster and more efficiently.
Wealth ManagementKYCPrivate BankingSource of Wealth