Enhanced Due Diligence in Mauritius: when standard KYC stops being enough
Enhanced Due Diligence, EDD, is the layer of investigation that sits on top of standard customer due diligence when a relationship is rated high risk. It is not a different process. It is the same process, with deeper sourcing, tighter thresholds, and a higher standard of evidence. In Mauritius, the trigger to apply EDD comes from the Bank of Mauritius and FSC guidelines, the FATF recommendations, and your own internal risk-based approach.
When EDD is required
EDD is not optional once a relationship hits one of the standard triggers. The most common in Mauritius are politically exposed persons and their close associates, customers in or connected to high-risk third countries, including FATF-listed and grey-listed jurisdictions, opaque or unnecessarily complex ownership structures, customers in higher-risk sectors such as cash-intensive trading, crypto, real estate, or precious metals, transactions that are unusually large, complex, or lack a clear economic purpose, and non-face-to-face onboarding without compensating controls.
When two or more triggers stack, treat the relationship as high-risk by default and document the decision. Auditors and regulators are far more comfortable with a documented high rating than with an unjustified medium one.
The three families of risk factors
Risk factors fall into three groups, and a good EDD file engages with all three. Customer risk factors include the structure itself, such as nominee arrangements, bearer shares, or trustee relationships, and the customer profile, such as PEP status or a cash-intensive business. Product and transaction risk factors cover the relationship with you: the channel, the products consumed, the counterparties, and the source of funds. Geographic risk factors cover the countries involved in the customer, in the structure, in the funds, and in the counterparties, including any sanctions exposure.
What an EDD file should actually contain
A defensible EDD file goes beyond standard CDD in three ways. Sourcing is broader, with multiple independent sources for ownership, activity, and source of wealth. Thresholds are tighter, with beneficial ownership traced to 10% or even 5% rather than the 25% default. Evidence is stronger, with corroboration of the source of wealth and source of funds rather than self-declaration. Crucially, the file includes a written narrative that explains what the customer does, who controls them, where the money comes from, and why the relationship is acceptable given that risk picture.
Ongoing monitoring is part of EDD
EDD does not end at onboarding. High-risk relationships need more frequent reviews, typically annual at a minimum, with transaction monitoring tuned to the customer profile and event-driven triggers for changes in directors, shareholders, sanctions status, and adverse media. The Mauritius regulator, like every FATF-aligned regulator, expects to see evidence that you actually looked again after onboarding.
The cost of getting EDD wrong
Failing to apply EDD when it was warranted is the single most common finding in AML enforcement actions. It also carries the highest reputational cost, because the failure usually surfaces alongside a real money-laundering or sanctions event. The institutions that get this right are not the ones with the largest compliance teams. They are the ones with the cleanest data and the fastest path from a risk trigger to a complete picture of the counterparty. That is what Solantis exists to provide for Mauritius entities, with ownership, directors, and connected parties already linked and ready to query.