Enhanced Due Diligence vs Operational Efficiency
Confine EDD resources to genuinely elevated-risk customers per FATF Recommendation 19, applying simplified measures where permitted.
CyberTRIZ analysis · Regulatory contradiction R135 · one of 8,235 worked contradictions published by CyberTRIZ.AI
Regulations
Contradiction
Resolution
Reserve Enhanced Due Diligence (EDD) for customers with elevated risk while applying simplified measures where regulations permit.
Evidence
EDD Files
Customer Risk Register
AML Reviews
Kpis
EDD completion rate
High-risk customer reviews
Controls that address this (13)
FATF-AML-001 - Implement Risk-Based AML/CFT Approachoperational · critical priority · Implement a risk-based approach to AML/CFT covering: national risk assessment awareness, institutional risk assessment, risk-based allocatioFATF-CDD-001 - Implement FATF-Standard Customer Due Diligenceoperational · critical priority · Apply CDD measures to all customers: identify and verify customer identity, identify beneficial owners, understand the purpose of the busineFATF-R1-001 - Institutional AML/CFT Risk Assessmentgovernance · critical priority · Conduct a comprehensive institutional AML/CFT risk assessment covering: products and services, customer types, delivery channels, and geogra