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Client Due Diligence Checklist

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CLIENT DUE DILIGENCE CHECKLIST

This Client Due Diligence Checklist ("Checklist") documents the due diligence performed in connection with the engagement between Client Name: and Firm Name: . Engagement Date: .

Recitals

WHEREAS, Client seeks to engage Firm to provide professional services as described in the engagement letter and those services require Firm to conduct client due diligence and satisfy applicable anti-money laundering, counter-terrorism financing, sanctions screening and related regulatory obligations; and

WHEREAS, Firm requires satisfactory documentation and representations from Client in order to accept and continue the engagement and to maintain records and monitoring consistent with Firm policies and applicable law; and

WHEREAS, the parties wish to record the scope and outcome of the due diligence performed as of the Engagement Date identified above.

NOW THEREFORE, in consideration of the mutual covenants contained herein, the parties agree as follows:

1. Scope of Due Diligence

1.1 Firm has conducted reasonable due diligence appropriate to the nature of the engagement, which includes verification of identity, assessment of beneficial ownership, screening against sanctions and politically exposed persons lists, review of source of funds and source of wealth, and review of relevant corporate or trust documentation where applicable. The scope of checks required and performed is set out in this Checklist.

2. Client Identity and Verification

2.1 Identity documents received and reviewed (check all that apply):

Passport or national identity card provided

Driver's license provided

Secondary identity document (e.g., government-issued ID, birth certificate) provided

3. Beneficial Ownership and Entity Documentation

3.1 For corporate, partnership, trust, or other non-natural person clients, the following items were requested and reviewed as applicable:

Corporate registry extract or equivalent

Articles of incorporation / formation documents

Bylaws / operating agreement / partnership agreement

Shareholder / member register indicating ownership percentages

4. Source of Funds and Source of Wealth

4.1 Client has provided documentation supporting the source of funds for anticipated transactions and, where required, broader source of wealth documentation. Firm has assessed whether the provided information is consistent with the expected profile of the client.

Bank statements received

Employment or business income documentation received

Sale of assets / investment proceeds documentation received

5. Screening and Risk Assessment

5.1 The following screening and risk-assessment steps were completed:

Sanctions screening completed

Politically exposed persons (PEP) screening completed

Adverse media checks completed

6. Ongoing Monitoring and Review

6.1 Firm will apply ongoing monitoring commensurate with the assessed risk. The parties acknowledge the monitoring frequency set out below and the conditions that will trigger an enhanced review.

7. Record Retention and Confidentiality

7.1 Firm will retain copies of identity documents, due diligence notes, screening results and related records for the period required under applicable law and Firm policy. Client consents to such retention and to Firm's use of the information for compliance and recordkeeping purposes.

7.2 Firm will maintain the confidentiality of Client information in accordance with the engagement letter, except where disclosure is required by law, regulation, or for compliance with sanctions, tax or public authorities.

8. Representations and Warranties

8.1 Client represents and warrants that all information and documentation provided to Firm is true, complete and not misleading in any material respect as of the Engagement Date and that Client will promptly notify Firm of any material changes.

8.2 Firm's acceptance of this Checklist and continuation of the engagement is conditioned upon the accuracy of Client representations and Firm's satisfaction with the due diligence performed. Firm reserves the right to decline or terminate the engagement where due diligence results or subsequent information indicate unacceptable compliance or reputational risk.

9. Findings and Conclusion

9.1 Summary of findings (select applicable and provide summary):

No material issues identified

Minor issues identified (mitigated)

High risk or unresolved issues identified

10. Notices, Amendments, Waiver

10.1 Notices under this Checklist shall be in writing and delivered to the addresses specified below. Any amendment or waiver of this Checklist must be in writing and signed by both parties. Failure to insist upon strict performance of any provision is not a waiver of any right.

11. Governing Law; Entire Agreement; Severability; Counterparts

11.1 Governing Law. This Checklist shall be governed by and construed in accordance with the laws of the jurisdiction specified in the engagement letter between the parties, without regard to conflict of laws principles.

11.2 Entire Agreement. This Checklist, together with the engagement letter, constitutes the entire agreement between the parties with respect to the subject matter hereof and supersedes all prior understandings and agreements, whether written or oral, concerning such subject matter.

11.3 Severability. If any provision of this Checklist is held to be invalid or unenforceable in any respect, the validity and enforceability of the remaining provisions shall not be affected.

11.4 Counterparts. This Checklist may be executed in counterparts, each of which shall be an original but all of which together constitute one and the same instrument.

Acknowledgment

By signing below, Client and Firm acknowledge that they have reviewed the due diligence recorded in this Checklist, that the information provided is accurate to the best of their knowledge, and that they understand Firm's rights to decline or terminate services where client information is unsatisfactory.

Client Printed Name:

By:

Date:

Firm Printed Name:

By:

Date:

Enter text✕

What the Client Due Diligence Checklist Is

The Client Due Diligence Checklist is a structured form used to collect, verify, and record essential identification, ownership, and risk information about a client before establishing or continuing a business relationship. It standardizes KYC (know your customer) and anti-money laundering screening steps, lists required supporting documents, documents verification methods, and captures approval or escalation decisions. The checklist creates an auditable record that supports regulatory reporting, internal policy enforcement, and periodic monitoring. It is compatible with electronic completion and retention frameworks governed by ESIGN and state UETA laws.

Why a Checklist Matters for Compliance and Risk Control

A Client Due Diligence Checklist reduces onboarding risk by ensuring consistent identity verification, documenting source-of-funds checks, and creating evidence for audits and regulators.

Why a Checklist Matters for Compliance and Risk Control

Who Typically Completes a Client Due Diligence Checklist

Teams across compliance, front-office, and legal functions use this checklist to collect and validate client data during onboarding and significant relationship changes.

  • Compliance officers responsible for AML/KYC program enforcement and recordkeeping.
  • Relationship managers or account teams collecting client information and initial documents.
  • In-house counsel or risk teams reviewing high-risk clients or escalation cases.

The checklist also supports auditors and examiners by preserving verification evidence and decision notes in a single, consistent record.

Step-by-step: Completing the Checklist

Follow these sequential steps to complete client due diligence consistently and in a compliant manner.

  • 01
    Gather: Collect IDs, formation documents, and source-of-funds records.
  • 02
    Verify: Confirm identity with credential checks and document review.
  • 03
    Assess: Assign a risk rating and note mitigations or enhanced checks.
  • 04
    Record: Sign, date, store, and schedule periodic refreshes.

Configuring an Online Diligence Workflow

Set up fields, verification methods, and integrations to streamline collection and provide audit-ready records.

Field Configuration
Identity Verification SMS code, KBA, or ID credential analysis
Document Types Accepted PDF, JPG, PNG, DOCX for identity and formation documents
Conditional Fields Show beneficial ownership fields for entities only
Audit Trail Storage Retain IP, timestamp, and action logs in secure storage

Technical Requirements for eSubmission and Signing

Ensure your platform supports secure uploads, the right file types, and integrations that match your compliance workflow.

  • Browser Support: Modern Chrome, Edge, Safari, and Firefox
  • File Formats: PDF, DOCX, JPG, PNG accepted
  • Common Integrations: CRM, document storage, and KYC providers

Choose a platform that records an audit trail and supports the authentication methods your compliance program requires.

Digital Collection and Signature Flow

A standard online flow reduces friction and preserves verification evidence for audits and later review.

  • Upload: Staff uploads checklist and documents to the system
  • Place Fields: Assign name, date, signature, and attachment fields
  • Send: Deliver signing link or email invite to client
  • Complete: Client signs; system stores signed file and certificate

Core Elements of a Professional Checklist

A robust checklist combines identity data, risk scoring, supporting evidence, and clear approval steps for auditability.

Identity Details

Collect full legal name, date of birth or formation date, and government-issued ID numbers to establish a primary identity record.

Risk Rating

Provide a standardized risk score with reasons and required mitigations, enabling consistent escalation and enhanced due diligence.

Source of Funds

Document the origin of funds or assets with bank statements, contracts, or declarations to meet AML program requirements.

Supporting Documents

Attach proof of identity, formation documents, ownership schedules, and any third-party verification reports for evidence.

Monitoring Plan

Specify review timing, triggers for refresh, and event-based monitoring instructions to ensure ongoing compliance.

Approval Trail

Include signoff fields for preparer, reviewer, and approver with dates to create an auditable decision history.

Required Security and Compliance Controls

Encryption: TLS 1.2/1.3 in transit; AES-256 at rest
HIPAA: BAA required for protected health information
Audit Trail: Capture IP, timestamps, and action logs
Access Controls: Role-based access and least privilege
Signer Authentication: Email, SMS, KBA, or stronger methods
Retention Policy: Store signed records per regulatory schedule

Common Preparation Errors to Avoid

  • Submitting incomplete or expired identity documents that force repeat collection and delay onboarding.
  • Mismatched names between ID and account records that create verification failures and require manual reconciliation.
  • Failing to document source-of-funds leads to downstream AML inquiries and potential account restrictions.
  • Omitting reviewer notes or approval signatures, leaving decisions undocumented and increasing compliance risk.

Potential Consequences of Inadequate Due Diligence

Regulatory Fines: Civil penalties and enforcement actions
AML Violations: Criminal and civil exposure for program failures
Reporting Errors: Incorrect information returns and penalties
Backup Withholding: 24% withholding for missing TINs
Reputational Harm: Customer and market trust erosion
Contract Risk: Agreements voided for improper signatory authority

Timing Expectations and Refresh Cadence

Set clear deadlines for initial collection, verification, and periodic refreshes to keep client files current and defensible.

Initial Collection:

Collect checklist and core documents before account activation or service start

Verification Window:

Complete identity and document verification within 30 days of collection

Periodic Refresh:

Re-evaluate low-risk clients at least every 36 months; higher-risk more often

Event-Based Update:

Trigger refresh on material changes such as ownership or control shifts

Audit Preparedness:

Ensure all evidence is retained before scheduled examinations

Key Milestones in the Due Diligence Workflow

Track milestone completion from intake through approval to ensure clarity and accountability across teams.

01

Intake Submitted

Client data and documents are uploaded by relationship manager

02

Identity Verified

Verification checks completed and discrepancies noted

03

Risk Decisioned

Risk rating assigned and mitigations specified

04

Final Approval

Authorized reviewer signs off and file is retained

eSignature Pricing and Feature Snapshot

Compare starting price, trial availability, bulk send, audit trails, HIPAA support, and envelope caps across vendors with signNow listed first.

signNow DocuSign Adobe Sign PandaDoc HelloSign
Starting Price $8/user/mo $15/user/mo $14/user/mo $19/user/mo $15/user/mo
Free Trial 7-day free trial Varies Varies Varies Varies
Bulk Send Yes Yes Yes Yes No
Audit Trail Yes Yes Yes Yes Yes
HIPAA Compliant Yes Yes Yes No No
Envelope Cap No envelope cap 100 envelopes/user/year Varies by plan Varies by plan Varies by plan

FAQs: Common Questions About the Checklist

Answers to frequent questions about legality, signatures, notarization, corrections, and storage for client due diligence records.


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