Client Due Diligence (CDD) Record and Identity Verification Checklist

The full CDD record for every client type – individuals, sole traders, partnerships, LLPs, companies, trusts, charities and estates – with beneficial ownership, register checks, screening, purpose of the relationship and sign-off.

Editable Word document
10
10pages
Guidance notes included
aml consultancy solutions

Accountancy practice – compliance & management

Client Due Diligence (CDD) Record and Identity Verification Checklist

About this document

What it’s for

The evidence that you have identified and verified each client and its beneficial owners, understood its ownership and control, checked the public registers, screened it and understood the purpose of the relationship, as required by regulations 27 to 30A of the Money Laundering Regulations 2017 (as amended in 2026). Supervisors, including ACCA, test a sample of these records on every monitoring review, and incomplete CDD is the most common failing they find.

When to use it

  • Before accepting any new client or any new service for an existing client
  • When bringing inherited or acquired clients up to standard
  • When a review finds the information held is out of date or inadequate

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  • Part 1 – Client and engagement
  • Part 2 – Identification of the client
  • Part 3 – Beneficial owners and controllers
  • Part 4 – Verification of identity
  • Part 5 – Register checks and discrepancies
  • Part 6 – Screening
  • Part 7 – Purpose, nature and expected activity
  • Part 8 – Review and sign-off
  • Appendix A – Acceptable evidence
  • Appendix B – Certified copy wording

How to complete it

  • Complete Part 1 and the section in Part 2 for the client type, then Parts 3 to 8 for every client
  • Record what you saw and how you verified it – not just “ID seen”
  • Attach copies or the full electronic verification report, and keep them with this record
  • Do not start work until Part 8 is signed, unless the MLRO has approved a timing exception in writing

Key points to check

  • Complete the Client Risk Assessment Form first – it decides whether standard, simplified or enhanced due diligence applies
  • Use the Source of Funds and Source of Wealth form for high-risk clients and PEPs
  • Appendix A lists acceptable documents and Appendix B the wording for certified copies

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Accountancy practice – compliance & management

£20

for every document in this category

Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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