Examples of EDD measures firms should apply in all other high-risk situations include:

a) obtaining additional customer information during identification, such as the source of funds;

b) applying additional verification measures from a wider variety of reliable and independent sources (e.g. checking against online databases) in order to verify the customer’s or beneficial owner’s identity;

c) obtaining additional information about the intended nature of the business relationship, for example by asking customers about their business or the jurisdictions to which they intend to transfer E-money;

d) obtaining information about the merchant/payee, in particular where the E-money issuer has grounds to suspect that its products are being used to purchase illicit or age-restricted goods;

e) applying identity fraud checks to ensure that the customer is who they claim to be;

f) applying enhanced monitoring to the customer relationship and individual transactions;