Standard Chartered Bank

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)

Customer Due Diligence

For the highest-risk customers, run a deeper, joined-up due diligence package (extra evidence, senior sign-off, closer monitoring) and make sure it actually happens before and during the relationship.

Starting threshold:

EDD mandatory on any reg.33 trigger; require 100% of the defined EDD evidence pack complete plus recorded senior approval before activation; enhanced ongoing monitoring with review at least every 12 months (every 6 months for PEPs and the highest-risk band); EDD review more than 30 days overdue is a reportable control breach.

First-line owner:

Relationship Management / KYC Operations with EDD specialists

Screening

Checks the names, banks and countries on each payment message against sanctions lists in real time and holds anything that hits before the money leaves.

Starting threshold:

Fuzzy match score >= 85% holds the payment for Level 1 review; exact matches on structured identifiers (BIC, IBAN, sanctioned vessel/IMO) or a prohibited destination country hard-block automatically.

First-line owner:

Payments Operations / Sanctions screening team

Screening

Before banking another bank, the firm checks that respondent's ownership, controls and customers so it does not unknowingly process crime or sanctions risk on their behalf.

Starting threshold:

No relationship without completed EDD and senior sign-off; respondent or owner screening hit at fuzzy score >= 85% holds onboarding for review; payable-through / nested access prohibited unless specifically assessed and controlled. Shell banks are an automatic decline.

First-line owner:

Correspondent Banking / Financial Institutions relationship team

Screening

Checks trade finance deals for tell-tale signs of laundering, such as over- or under-priced goods, dual-use items and shell counterparties, before the firm finances or pays for them.

Starting threshold:

Counterparty/vessel/port screening hit at fuzzy score >= 85% holds the transaction; invoiced unit price deviating more than 25% from the benchmark band, or any dual-use / controlled-goods or sanctioned-port indicator, routes to mandatory trade-compliance review.

First-line owner:

Trade Finance Operations / Trade Compliance team