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Ad Hoc EDD

Ad Hoc Enhanced Due Diligence (EDD) is a specialized verification workflow triggered when an already onboarded customer requires further review due to changes in their risk profile or manual intervention by the compliance team.

Unlike other entitlements, the Ad Hoc EDD cannot be initiated by the client via the API. It is exclusively triggered internally by DLT.

Entitlement Summary​

FieldValueDescription
Nameadhoc_eddThe system name of the entitlement (exclusively triggered by DLT).
Applies ToPersonThis entitlement is triggered for individual customers.
Prerequisites1. Onboarded: The target Person must have a successfully completed onboarding.
OutcomeUpon completion, the review result is set. Success allows for the release of locks, while failure results in continued restrictions.

Triggers​

The Ad Hoc EDD entitlement is automatically or manually initiated based on the following criteria:

  • Risk Score Change: If an automated risk assessment determines that a customer's risk score has exceeded acceptable thresholds, the workflow is triggered to mitigate potential risks.
  • Compliance Manual Trigger: A compliance analyst may manually initiate an Ad Hoc EDD if suspicious activity is detected or if periodic review requirements are met.

Operational Workflow​

When an Ad Hoc EDD is triggered, the system may apply restrictions to the account to ensure compliance during the review process.

1. Account Locking​

Upon initiation, the system may apply:

  • Funding Lock: Prevents deposits and withdrawals.
  • Trading Lock: Prevents the execution of new trades.

2. Requirements Request​

The system will issue a requirementsQuestionnaire webhook to your application.

  • Webhook Reason: adhoc_edd

This webhook contains the identifiers for the questionnaires or document requests that the customer must fulfill. Your application must fetch these requirements and present them to the user.

3. Submission & Review​

The customer must provide the requested information (e.g. updated Proof of Address, Source of Funds, selfie). Once submitted, the compliance team reviews the data.

This process may be iterative. If the submitted information is insufficient, a new requirementsQuestionnaire may be issued with further requests.

Completion & Results​

The workflow concludes with an assessment by the compliance team.

Success​

If the EDD requirements are met and the risk is deemed acceptable:

  • Release of Locks: If locks were applied, their release is not automatic upon approval. The workflow waits for an explicit unlock event from the compliance system. Once received, Funding and Trading locks are only removed if they are not also required by other active compliance processes.
  • Webhook: You will receive an entitlementCompleted webhook.

Failure​

If the customer fails to provide the required information or if the compliance review remains negative:

  • Locks Retained: Any locks applied during the process remain active to prevent further activity.
  • Webhook: You will receive an entitlementFailed webhook.
  • Next Steps: The account may be subject to further offboarding procedures.

Flow Diagram​