Daily Compliance Brief — Enhanced Due Diligence Controls Face Increasing Governance Scrutiny
June 12, 2026
Signal
Recent regulatory activity highlights growing attention on the effectiveness of enhanced due diligence frameworks applied to higher-risk customers, business relationships, and geographic exposures.
Reviews have highlighted inconsistent application of enhanced due diligence measures, insufficient evidence supporting risk mitigation decisions, and limited linkage between due diligence findings and ongoing monitoring activities.
Regulatory priorities continue to emphasize demonstrable governance over higher-risk relationships, with greater focus on whether enhanced due diligence measures remain proportionate to evolving financial crime exposure.
Why it matters
Governance teams should review enhanced due diligence frameworks to determine whether escalation criteria, review procedures, and risk mitigation measures remain appropriate for current risk conditions.
Control environments may require enhancement to ensure due diligence findings, ownership information, adverse information, and transactional risk indicators are reflected consistently across monitoring and customer risk assessment processes.
Independent review processes should ensure enhanced due diligence decisions are documented clearly, challenged where necessary, and supported by effective oversight of higher-risk customer populations.