Customer due diligence is one of the most visible aspects of AML compliance. The 2026 reforms refine several customer due diligence requirements and seek to clarify when standard, simplified and enhanced measures are appropriate.

Businesses that are subject to AML regulations are generally required to verify the identity of customers before entering into certain business relationships or transactions. This often involves obtaining documents such as passports, driving licences, proof of address and company registration information.

Where the customer is a company, partnership or other organisation, businesses may also need to identify individuals who ultimately own or control the entity. These individuals are often referred to as beneficial owners.

The practical consequence for many businesses is that transactions may be delayed until satisfactory identification evidence is provided. Although sometimes viewed as burdensome, these procedures are intended to prevent criminals from hiding behind complex corporate structures or false identities.

Businesses may also be expected to apply increased scrutiny where transactions appear unusually large, unusually complex, or lack an obvious economic or lawful purpose. This reflects a growing regulatory expectation that firms should understand not merely who their customers are, but also the rationale behind significant or unusual transactions.

For ID templates, see the corporate Anti-Money Laundering Client Identification Checklist and the business Anti-Money Laundering Customer Identification Checklist