Pre-transaction, pre-retainer, and pre-admission screening for counsel, private equity, financial institutions, and family offices. Beneficial ownership, sanctions, PEP, and adverse-media coverage anchored in Tier-1 data.
Enhanced Due Diligence (EDD) sits between standard KYC and full investigative work. It is the layer counsel, PE funds, and family offices reach for when a counterparty's risk profile requires more than a database screen but doesn't yet warrant a full tracing mandate. The objective is a documented, defensible view of beneficial ownership, litigation exposure, sanctions proximity, and adverse-media signal.
Coldstorm's EDD methodology follows the FATF Recommendations 24 and 25 framework (revised 2022–2024), which requires a multi-source approach: registers supplemented by intermediary-held information, cross-referenced against sanctioned-entity lists and PEP registers, and verified rather than accepted at face value. The March 2024 FATF Guidance on Beneficial Ownership of Legal Arrangements is the current operational baseline we build against.
Every EDD report includes a source-tier citation for every flagged item, a beneficial-ownership schematic, an identified-exposure register, and an analyst commentary on the strength of each finding. The work is instructed under privilege where counsel requires it. Turnaround is typically 5 to 10 business days for a named entity across three jurisdictions.
Verifying target, GP, and LP declarations before signing. Identifying concealed beneficial ownership and sanctions exposure.
Pre-distribution, pre-investment, and pre-counterparty engagement screening for UHNW clients.
Correspondent banking reviews, high-risk client onboarding, and periodic EDD refreshes for material relationships.
Pre-retainer verification where the client or a counterparty requires more than standard onboarding.
Pre-admission or pre-distribution verification where beneficiary or settlor declarations require substantiation.
Supporting case build-up with structured beneficial-ownership mapping.
Named subject, jurisdictions, decision trigger, and delivery deadline confirmed. Conflict check complete. Fee estimate and SLA issued. Counsel or principal instructs.
Identification of applicable Tier-1 sources (registries, regulated intermediary disclosures, court records), Tier-2 (commercial beneficial-ownership datasets, property records), and Tier-3 (open-web adverse media).
Structured retrieval and timestamped archiving from each tier. Subject, counterparties, operating structures, and any declared beneficial owners cross-referenced.
Findings weighted by source tier. False-positive suppression. Narrative built around the three risk axes: identity verification, counterparty exposure, jurisdictional risk.
Written report with executive summary, flagged findings, source-tier citations, and analyst recommendation. Delivered to instructing counsel or principal only.
| Matter type | Scope profile | Timing |
|---|---|---|
| Named individual UHNW | 3 jurisdictions | 5–7 business days |
| Corporate counterparty | PE or FI transaction | 7–10 business days |
| Full beneficial-ownership mapping | Complex structure | 10–14 business days |
| Periodic EDD refresh | Existing relationship | 3–5 business days |
Every engagement is quoted after a confidential scoping call. Fees reflect matter complexity, jurisdictions in scope, and delivery timeline. Engagements instructed by counsel are treated as privileged work product and delivered to the retaining party only.
Standard KYC verifies identity and screens for known risk lists. Enhanced Due Diligence adds structural analysis of beneficial ownership, adverse-media synthesis, PEP-proximity mapping, and cross-jurisdictional verification. Required by the FATF framework for high-risk relationships.
Consolidated coverage of OFAC (US Treasury), EU Consolidated, UK OFSI, UN Security Council, and major PEP registers, cross-referenced against named-entity subjects. Adverse-media coverage via commercial aggregators and structured open-source review.
Yes. FATF's March 2024 guidance explicitly requires a broader view than the 25% test, including effective control through voting rights, director-appointment powers, and contractual arrangements. We build a full control map, not just an ownership map.
Luxembourg RBE is accessible to us as a credentialed AML/CFT professional under the February 2025 framework. BVI BOSS access requires triangulation via registered-agent disclosures and related-party filings. Switzerland is intermediary-led under current AMLO-FINMA. Each jurisdiction has a specific operational path.
Reports instructed by counsel are treated as privileged work product. Delivered to the retaining party only. No external contact made without written authorisation.
Urgent matters receive a scoped response within twelve business hours. Longer engagements begin with a paid scoping consultation under privilege where counsel instructs.
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