EFG Private Bank

Customer Due Diligence

For a specific large or unusual deposit, establish and evidence where that exact money came from before it is used.

Starting threshold:

Verify source of funds for any single inflow >= GBP 10,000 (or local equivalent) or aggregated inflows >= GBP 10,000 in 30 days; lower to GBP 0 (verify all) for high-risk and PEP relationships; always verify where the payer differs from the customer or the funds originate in a high-risk third country (reg.33).

First-line owner:

Relationship Management / Onboarding with KYC Operations

Customer Due Diligence

For high-risk and PEP customers, understand and prove how they built their overall wealth (not just one deposit), and make sure that story is plausible and independently corroborated.

Starting threshold:

Mandatory documented and corroborated source of wealth for all high-risk and PEP relationships before onboarding; flag for escalation where corroborated wealth covers less than 75% of estimated net worth, or where wealth exceeds 10x the customer's known/declared legitimate income or official remuneration with no documented explanation.

First-line owner:

Relationship Management (private banking / wealth) with KYC support

Customer Due Diligence

Spot customers (and their close family and associates) who hold or held prominent public office, then apply extra checks and senior approval because they carry higher corruption risk.

Starting threshold:

PEP screening match score >= 85% auto-routes to manual adjudication; all confirmed PEPs require senior management approval before activation; family members and close associates screened to the same standard; ex-PEP de-classification only after a documented risk assessment and a minimum 12-month stand-down (longer for foreign/high-corruption-risk roles).

First-line owner:

Screening Operations / KYC team