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AML: EDD for Complex Cross-Border Structures

Writer: Arne MielkenArne Mielken

Updated: Mar 7

Exploring EDD for complex structures in cross-border trade and international compliance to mitigate risks and ensure transparency in global transactions.


Understanding Complex Structures in Cross-Border Trade and International Compliance


A hooded figure with money, cargo ship, planes, and forklifts in a busy industrial port with a globe backdrop, suggests global trade.
Navigating Enhanced Due Diligence: A depiction of addressing complexities in cross-border trade and international compliance for risk mitigation and transparency in global transactions.

When it comes to cross-border trade, one of the key pillars of compliance is conducting thorough Customer Due Diligence (CDD). This process becomes especially critical when dealing with complex corporate structures. As businesses expand across borders, it’s not uncommon to encounter ownership models that appear convoluted, and while these structures might have legitimate business reasons, they also pose potential risks that need to be understood and mitigated.


In this blog entry, we’ll dive into how to conduct CDD on complex ownership structures and the heightened scrutiny that must be applied in these cases and how to do it.


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We cover the following topics in this blog


  • Conducting CDD on Complex Structures

  • Background Checks for Customers and Beneficial Owners

  • Investigation Elements in Complex Ownership Structures

  • Additional Information to be Obtained in EDD Cases

  • Purpose and Intended Nature of the Business Relationship

  • Enhanced Verification of Beneficial Ownership

  • Ongoing Monitoring and Review

  • Third-Party Verification and Investigations

  • Additional Documentation for High-Risk Cases

  • Senior Management Approval in EDD

  • Importance of Documentation in CDD and EDD

  • EDD in International Trade and Compliance

  • Case Study: EU Sanctions Against Russia and EDD for High-Risk Items

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