Editorial reference date: 7 November 2026
Customer due diligence (CDD) rests on internationally recognised principles, while its practical requirements depend on the applicable legal framework. Researching CDD therefore involves establishing who is subject to the rules, which activities they cover, and when particular requirements apply.
This guide brings together selected official sources for eight jurisdictions: the European Union, the United Kingdom, the United States, Switzerland, Singapore, Hong Kong, Australia and South Africa. It identifies the main points of entry into each framework and highlights differences in scope, legal status and implementation dates. The coverage of Singapore and Hong Kong focuses on banking.
For the underlying concepts, see the Customer Due Diligence glossary entry. This guide provides the next step: locating the standards, legislation and supervisory materials relevant to a particular jurisdiction.
Understanding the sources
CDD requirements are documented at several levels:
| Source level | Role in the framework |
|---|---|
| International standards | Establish shared expectations that jurisdictions implement through their own legal and regulatory arrangements. |
| Legislation and binding rules | Define obligations for the institutions, professions and activities within their scope. |
| Supervisory guidance and official explanations | Explain how requirements should be interpreted or implemented. Their legal weight depends on the framework under which they are issued. |
A source’s publication date alone does not establish whether it governs a particular situation. Amendments, commencement provisions, application dates and transitional arrangements all matter.
The references below link to the wirtschaftsforensik.ch source library, which records bibliographic details, version information and links to the official publications.
The international baseline
The FATF Recommendations provide the principal international reference framework. Recommendation 1 establishes the risk-based approach, Recommendation 10 addresses customer due diligence, and Recommendation 11 covers record-keeping. The Interpretive Note to Recommendation 10 provides further detail on CDD measures. This guide uses the June 2026 version. The applicable obligations for individual institutions depend on implementation in the relevant jurisdiction. (FATF Recommendations)
For banks, the Basel Committee’s Sound management of risks related to money laundering and financing of terrorism connects CDD with wider risk management. Sections II.2–II.5 address customer acceptance, identification and risk profiling, ongoing monitoring, and information management. The July 2020 guidelines provide a supervisory reference point; their implementation and legal effect must be established within each jurisdiction. (Basel Committee on Banking Supervision)
European Union
Coverage: Entities and professions subject to the applicable AML legislation in the relevant Member State.
The EU framework requires attention to both national implementation and forthcoming directly applicable rules.
Directive (EU) 2015/849, as amended, remains a central reference for national AML legislation at this guide’s editorial date. Chapter II addresses CDD, with Article 13 setting out the principal measures. A jurisdiction-specific assessment must also examine the relevant Member State’s implementing legislation and applicable sectoral requirements. (Directive (EU) 2015/849)
Regulation (EU) 2024/1624, commonly known as the AML Regulation or AMLR, has entered into force and generally applies from 10 July 2027. Article 90 provides a later application date of 10 July 2029 for specified categories of obliged entities. Chapter III contains the CDD provisions, including Article 20 on CDD measures and Article 26 on ongoing monitoring. As at November 2026, these requirements form part of the forthcoming framework. (Regulation (EU) 2024/1624)
United Kingdom
Coverage: Businesses and professions defined as “relevant persons” under the Money Laundering Regulations.
The main legislative starting point is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, SI 2017/692, as amended.
Part 3 addresses CDD. Regulations 27 and 28 explain when CDD is required and what it entails. Regulations 30 and 31 address the timing of verification and the consequences of being unable to complete the required measures. (UK Money Laundering Regulations 2017)
Research should use the amended legislation and identify the relevant supervisor and sectoral guidance. The original 2017 text provides the historical starting point; subsequent amendments determine the requirements applicable at a later date.
United States
Coverage: Covered financial institutions, including banks and specified securities, investment and futures-market institutions.
FinCEN’s CDD Rule resource page provides access to the rule, explanatory materials and subsequent developments. Within this framework, 31 CFR § 1010.230 specifically addresses beneficial ownership requirements for legal entity customers. Its definitions, exclusions and exemptions are important when determining whether a particular customer or institution falls within scope. (FinCEN: CDD Rule; 31 CFR § 1010.230)
FinCEN Order FIN-2026-R001, issued on 13 February 2026, provides relief from repeating beneficial ownership identification and verification at every additional account opening. Subject to the order’s conditions, institutions may limit these measures to the customer’s first account opening, subsequent circumstances that reasonably call existing information into question, and occasions required by risk-based ongoing CDD procedures. Other applicable Bank Secrecy Act and AML/CFT obligations continue. (FinCEN: FIN-2026-R001)
Financial institutions’ CDD duties and companies’ beneficial ownership reporting obligations belong to separate regulatory frameworks and require separate analysis.
Switzerland
Coverage: This section focuses on financial intermediaries. Article 2 of the Anti-Money Laundering Act establishes the statutory scope.
The Anti-Money Laundering Act, commonly referred to by its German abbreviation GwG, SR 955.0, provides the legislative starting point. Articles 3–7 address identification of the contracting party, establishment of beneficial ownership, renewed verification, additional due diligence measures and documentation. The consolidated version recorded in the source library is dated 1 October 2026. (Swiss Anti-Money Laundering Act)
FINMA’s anti-money laundering overview explains the supervisory framework and directs readers to further requirements. Depending on the institution, these include the FINMA Anti-Money Laundering Ordinance and other sectoral rules. The overview helps identify the relevant framework; the underlying instruments establish the binding requirements. (FINMA: Combating money laundering)
Singapore
Coverage: Banks within the scope of MAS Notice 626.
MAS Notice 626 — Prevention of Money Laundering and Countering the Financing of Terrorism — Banks sets binding requirements for the banks it covers. Paragraph 6 addresses CDD, paragraph 7 simplified CDD, and paragraph 8 enhanced CDD.
The Notice was issued on 28 March 2024. The amendment recorded on the MAS website is dated 30 June 2025 and took effect on 1 July 2025. These dates distinguish the current instrument from earlier versions bearing the same Notice number. (MAS Notice 626)
Other financial sectors are governed by their own MAS notices. Establishing the institution’s regulatory category is therefore an essential first step.
Hong Kong
Coverage: This section focuses on Authorized Institutions supervised by the Hong Kong Monetary Authority.
The Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), Cap. 615, contains statutory CDD and record-keeping requirements in Schedule 2. Its scope and exceptions must be assessed for the institution or activity concerned. (Hong Kong AMLO, Cap. 615)
For banking, the HKMA Guideline on Anti-Money Laundering and Counter-Financing of Terrorism, designated AML-2, explains the statutory requirements and supervisory expectations. The version listed as current in the official repository was issued on 25 May 2023. Chapter 4 addresses CDD, Chapter 5 ongoing monitoring, and Chapter 8 record-keeping.
AML-2 is a statutory guideline. Paragraphs 1.3 and 1.6–1.8 explain its legal basis and significance. Other regulated sectors require reference to their own supervisory authorities and guidance. (HKMA AML-2: Guideline for Authorized Institutions)
Australia
Coverage: Reporting entities providing designated services within the Australian AML/CTF framework.
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006, as amended, and the AML/CTF Rules 2025 establish the principal legal framework. Part 2 of the Act addresses CDD, including section 26F, with further detail supplied by the Rules. (AML/CTF Act 2006; AML/CTF Rules 2025)
AUSTRAC’s CDD overview provides an accessible entry point into initial, ongoing and enhanced CDD under the reformed framework. It explains how customer identification, beneficial ownership, monitoring and risk-based review fit together. (AUSTRAC: Overview of customer due diligence)
The separate AML/CTF Transitional Rules 2026 allow eligible existing reporting entities to continue using specified pre-reform identification procedures for initial CDD, subject to conditions. Under section 7, the transitional period ends at the start of 31 March 2029, permitting their use no later than 30 March 2029. (AML/CTF Transitional Rules 2026, Part 3)
This arrangement concerns initial CDD. The new ongoing CDD obligations apply to the relevant existing reporting entities from 31 March 2026. AUSTRAC explains eligibility and transition planning, while the Department of Home Affairs provides context for the separate transitional instrument. (AUSTRAC: Transitional Rules 2026; Home Affairs: Transitional Rules)
South Africa
Coverage: “Accountable institutions” listed in Schedule 1 of the Financial Intelligence Centre Act, including financial institutions and specified businesses and professions.
The Financial Intelligence Centre Act 38 of 2001, as amended, establishes the statutory framework. Sections 21–21E contain central CDD requirements, including ongoing due diligence in section 21C. Section 42 addresses the Risk Management and Compliance Programme (RMCP).
The Act must be read with its amendments. The original 2001 publication alone does not establish the current requirements. (Financial Intelligence Centre Act)
The final FIC Guidance Note 7B, issued on 3 August 2026, explains implementation across four main areas: the risk-based approach, CDD, record-keeping and the RMCP. Its preface states that it replaces Guidance Note 7, Guidance Note 7A of February 2025, and the revised Guidance Note 7A of September 2025.
Guidance Note 7B is authoritative guidance issued under the statutory framework. Accountable institutions must take it into account when implementing their obligations, alongside the Act and related regulations. (FIC Guidance Note 7B)
Using the guide for further research
For a specific CDD question, work through four steps:
- Establish the scope. Identify the jurisdiction, institution or profession, and activity involved.
- Locate the applicable law. Check the relevant version, amendments, application dates and transitional provisions.
- Identify the CDD requirements. Examine customer identification, beneficial ownership, ongoing monitoring and record-keeping.
- Add the supervisory interpretation. Consult the relevant guidance, exceptions and implementation materials.
This guide provides a structured starting point for that research. Further coverage can extend to individual EU Member States, additional sectors and other jurisdictions. Each addition should make clear which entities it covers, what authority the source carries, and the period for which it is relevant.
