Due diligence trigger

Customer due diligence trigger checker

See whether a business relationship, an occasional transaction, the general 10,000 euro band, or the gambling 2,000 euro band points to due diligence.

Saved answers stay in closed lists: activity_band, role_band, kind_band, base_band, article_band, delay_band, documented_band, party_band, product_band, geo_band, channel_band, txn_band, sanctions_band, approval_band, refresh_band, owner_band, lead_band, manager_band, officer_band, independence_band, resource_band, escalate_band, policy_band, training_band, testing_band, fiu_band, relation_band, occasional_band, value_band, cash_band, linked_band, gambling_band, doubt_band, veracity_band, nation_band, entity_info_band, control_map_band, who_process_band, source_process_band, mismatch_band, arrangement_band, retention_band, update_band, plan_scope_band, plan_role_band, plan_risk_band, plan_policy_band, plan_function_band, plan_cdd_band, plan_cash_band, plan_report_band, plan_training_band, plan_retention_band, plan_nation_band, plan_ready_band, plan_delay_band

Is a business relationship being established?Is this an occasional transaction?Which value band applies?Is the payment cash?Are there linked transactions?Is this the specified gambling activity?Is the suspicion flag only yes or no?Is the identity-veracity flag only yes or no?Is a stricter national rule already known?

What the trigger screen checks

It applies the approved bands only. A business relationship is a trigger. An occasional transaction at or above 10,000 euro can be one. The 2,000 euro band is only for the specified gambling activity. Cash at or above 10,000 euro is an EU-limit review, and an unknown lower national limit stays a national review.

Who should use it

Teams that need a threshold screen before any due-diligence file is opened.

How results work

A yes on a suspicion or veracity flag goes to specialist review and does not decide that anything is suspicious. Unknown value bands stay in trigger review. Linked occasional payments are not added up here.

What this checks

Regulation (EU) 2024/1624 applies generally from 2027-07-10. Article 3(3)(n) and (o) categories apply from 2029-07-10. The regulation is directly applicable, and a Member State may keep a stricter rule where the regulation allows it. The EU large-cash baseline is EUR 10,000 and linked transactions count. A gambling figure of EUR 2,000 applies only to the specified activity.

Official sources

Threshold wording comes from Regulation (EU) 2024/1624 Article 19 for the general occasional figure, plus the cash article for the EUR 10,000 baseline. Do not copy one figure onto every scenario.

Limitations

No person name, identity document, bank detail, or transaction story is collected. The screen never says a cash payment is lawful or unlawful.

Using the trigger screen

Start with the relationship

Establishing a business relationship is enough for a likely due-diligence trigger.

Keep the gambling band local

Do not reuse 2,000 euro on a non-gambling occasional payment. That case follows the 10,000 euro band.

Ask about a lower national limit

If the stricter national cash rule is not already known, the result stays a lower-threshold review.

Trigger questions

Is 10,000 euro every scenario?

No. It is the general occasional figure and the EU cash baseline, not a universal rule.

What about linked payments?

They count, but this screen does not add raw amounts. Linked occasional cases stay in trigger review.