A Customer Due Diligence Analyst is an important function within banks and insurance companies. The position is becoming ever more important, especially with the new privacy regulations and an increasing focus on illegal flows of money from criminals, tax fraudsters and terrorists. A Customer Due Diligence (CDD) analyst investigates new and existing customers. If banks or insurers allow illegal flows of money through their organisation, they run a huge risk of prosecution by regulators or damage to their reputation should it leak to the media. It is the CDD analyst who investigates whether (potential) customers form risk factors for the organisation.
Customer Due Diligence investigation
Identifying illegal money flows starts with a thorough investigation into who is behind it. The unravelling of ownership structures of Limited companies, PLCs and foundations, both domestic and abroad, and looking at the activities and decision-makers of these entities. After unravelling the ownership structure, there must be sufficient current documentation collected to demonstrate that the bank or insurer has complied with its legal obligations for the identification and acceptance of new customers. These regulations have been created to ward off criminal companies guilty of financial and economic crimes, such as money laundering, fraud and the financing of terrorist activities.
Several sanction acts and lists apply to Dutch financial institutions. For example, the Netherlands has its own lists, but must also take the lists of other international institutions (such as the UN) and countries into account. The US sanctions list, in particular, can have a significant impact on the bank or insurer. Institutions therefore have to investigate their new and existing customers, taking appropriate action if a customer is on one of the sanction lists. Appropriate measures include freezing funds and assets, prohibiting the provision of financial resources or prohibiting the provision of financial services.
The exact work, of course, differs from organisation to organisation. But as a rule, it comes down to the CDD officer being assigned a customer. Subsequently, it is the CDD analyst’s responsibility to fully investigate this customer to the extent required by the organisation. Often, the CDD analyst will have to request the necessary documents from the account manager, customer or from other institutions such as the Dutch or foreign Chamber of Commerce. It is then up to the CDD analyst to check whether all documents have been collected and whether they comply with the guidelines of the bank or insurer. If everything is correct, approval can be given, and the account manager can continue to do business with this customer.
The CDD analyst is therefore responsible for overseeing whether the organisation adheres to laws and regulations.
In addition, the CDD Officer performs tasks including:
- Preparing compliance risk analyses;
- Continual monitoring of existing customer files for risks;
- Checking for unusual customer transactions;
- Reporting findings to management;
- And much more.
The following job requirements are stipulated for almost every CDD analyst vacancy:
- HBO/WO (higher vocational/academic education) working and thinking level;
- Sound investigative and analytical skills;
- Experience within financial markets;
- Good communication skills;
- Flexible and able to cope with stress.