Commerzbank AG

Customer Due Diligence

At sign-up, ask and record what normal looks like for this customer (how much, how often, to where) so monitoring can later spot when they behave nothing like that.

Starting threshold:

Profile mandatory for all customers; for higher-risk customers require itemised expected monthly turnover, expected corridors and expected counterparties. Flag for review where declared turnover exceeds 3x the income/turnover implied by occupation or filed accounts, or where declared geographies include high-risk jurisdictions not explained by the stated business.

First-line owner:

Onboarding / KYC Operations team

Customer Due Diligence

Score each new and existing customer for money-laundering risk from clear factors (who they are, what they do, where they are) so the firm spends most effort on the riskiest ones.

Starting threshold:

3-band model: high if any override (sanctions nexus, PEP, high-risk-jurisdiction nexus per reg.33) OR weighted score >=70/100; medium 40-69; low <40. High = EDD + annual review; medium = standard CDD + biennial review; low = simplified where permitted + triennial review.

First-line owner:

KYC Operations / Onboarding team (with model owned by Compliance)

Transaction Monitoring

Watches payments to and from higher-risk countries and routes, and flags activity that does not fit the customer or looks designed to disguise where money is really going.

Starting threshold:

Any payment to/from a high-risk jurisdiction not in the customer's declared geographies; OR cumulative value to high-risk corridors > 2x declared expectation in a rolling 30 days; OR 5+ low-value payments to a single TF-risk geography in a rolling 30 days.

First-line owner:

Financial Crime Operations Analyst (transaction monitoring / sanctions-adjacent)

Ongoing Monitoring

Every customer's identity and risk information is refreshed on a fixed schedule so the firm never relies on stale onboarding data.

Starting threshold:

Periodic review cadence: high risk every 12 months, medium risk every 24 months, low risk every 36 months; review case opens 30 days before due date.

First-line owner:

KYC / Client Lifecycle Management team

Ongoing Monitoring

When something material changes about a customer, the firm reviews them straight away instead of waiting for the next scheduled review.

Starting threshold:

Any catalogued trigger opens a review within 1 business day; high-severity triggers (sanctions/PEP confirmed match, SAR filed, change of control, new high-risk corridor exceeding GBP 10,000 in 30 days) escalate to enhanced review the same day.

First-line owner:

Financial Crime Operations / KYC Refresh team

Ongoing Monitoring

The customer's risk score is recalculated automatically from their real behaviour, so a customer who starts acting riskier is re-rated without waiting for a manual review.

Starting threshold:

Recompute scores nightly; auto-escalate the rating band when the residual score rises by 20 or more points or crosses a band boundary; require analyst sign-off before any rating downgrade takes effect.

First-line owner:

Financial Crime Analytics / Customer Risk team

Ongoing Monitoring

The firm vets and keeps watch over the agents and distributors who sell or move money on its behalf, so a rogue or nested agent cannot smuggle dirty money through its rails.

Starting threshold:

Re-due-diligence high-risk agents annually and others every two years; flag any agent whose monthly volume rises by 50 percent or more versus its trailing 6-month average, or that transacts in a corridor not in its approved profile; cap and review any agent originating volume above the limit set in its agreement.

First-line owner:

Agent / Partner Management team

Governance & Reporting

A clear, fast route for staff to raise a suspicion, for the MLRO to decide, and for a report to reach the authorities on time without tipping off the customer.

Starting threshold:

Internal report acknowledged by the nominated officer within 1 business day; SAR submitted to the NCA within 5 business days of the decision to disclose; DAML requested before any consent-dependent act, with no transaction processed against a pending defence.

First-line owner:

Financial Crime Operations / investigators raising and drafting internal reports

Governance & Reporting

Stop financial crime alerts and cases piling up unworked by tracking how old they are, fixing the cause, and stepping in fast when the queue grows.

Starting threshold:

Standard alerts worked within their queue SLA (e.g. 5 business days); high-risk and sanctions items within 1-2 business days; backlog trigger at a defined threshold (e.g. >2% of open items past SLA, or any sanctions item past SLA) invoking the remediation playbook; oldest open item tracked and capped.

First-line owner:

Financial Crime Operations team lead (queue management and throughput)