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Third-Party Due Diligence

  • 15 Minutes
  • For all staff
  • jurisdiction UK

Due diligence protects the organisation, and staff need to understand what is being done on third parties even where they are not the ones carrying it out. This 15-minute express module explains why third-party due diligence matters, how to conduct it properly, and how to recognise the red flags that should stop a relationship progressing.

Third parties create exposure under bribery, sanctions, modern slavery and fraud legislation, often on a strict basis where intent is irrelevant. Diligence completed at onboarding and never revisited misses everything that changes afterwards. Giving commercial and operational staff the ability to spot a red flag keeps the process alive between formal reviews, where most of the risk actually accumulates.
objectives

What you’ll learn in
this course

  • Understand the importance of conducting third-party due diligence
  • Be able to conduct third-party due diligence properly
  • Recognise the red flags when conducting third-party due diligence

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Build a resilient business with financial crime compliance training

Anti-money laundering failures cost UK firms an average of £186.5 million a year. Our training helps your people detect suspicious behaviour and uphold your company’s integrity.
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Money Laundering and Terrorist Financing Risks of Virtual Assets

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FSCS Deposit Protection

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COBS - Dealing and Managing

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Aggregation and allocation are where conflicts between clients become concrete, and the FCA has found allocation practice wanting in successive reviews. Best execution is also frequently treated as a policy document rather than a tested obligation. Training dealing and investment staff on the requirements keeps practice aligned with policy, which is exactly the gap supervisors look for.

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COBS - Client Categorisation

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Categorisation determines what the firm owes a client across the whole relationship, so an error at onboarding propagates through everything that follows. Elective professional classifications need documented assessment that frequently turns out to be thin. Training onboarding and client-facing staff protects the client's protections and keeps your files defensible when a relationship later goes wrong.

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Third-Party Due Diligence

Express 15 Minutes Financial Crime For all staff

Third parties create exposure under bribery, sanctions, modern slavery and fraud legislation, often on a strict basis where intent is irrelevant. Diligence completed at onboarding and never revisited misses everything that changes afterwards. Giving commercial and operational staff the ability to spot a red flag keeps the process alive between formal reviews, where most of the risk actually accumulates.

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Counter Terrorist Financing

Express 15 Minutes Financial Crime For all staff

Terrorist financing differs from money laundering in an important way: the sums are often small and the funds may be entirely legitimate in origin, which means transaction monitoring calibrated for laundering will miss it. Human judgement about context matters more here than pattern detection. Training staff to notice what does not fit is the control that actually applies.

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Economic Sanctions

Refresher 15 Minutes Financial Crime For all staff

Sanctions lists change without notice and often at short political notice, which means knowledge dates faster here than in almost any other compliance area. Liability frequently attaches regardless of intent. A short annual refresher keeps staff alert to the fact that yesterday's acceptable counterparty may not be today's, and reinforces the habit of escalating rather than assuming.

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Anti-Money Laundering [Financial services version]

Refresher 15 Minutes Financial Crime For all staff

Failing to report a suspicion is a personal criminal offence, which makes this one of the few areas where individual staff carry direct liability. Typologies also change as criminals adapt to new controls. A short annual refresher keeps recognition current and produces the dated training records the Money Laundering Regulations require firms to maintain.

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Appropriate Use of Communication Channels

In-depth 10 Minutes Financial Crime FCA Handbook For all staff

Regulators on both sides of the Atlantic have imposed very large fines specifically for off-channel communications, in cases where the underlying business was entirely legitimate. The failure is the record, not the conduct. Making the permitted list and the recording obligation explicit is the cheapest possible protection against a penalty that is entirely avoidable.

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Counter-Proliferation Financing

Express 10 Minutes Financial Crime For all staff

Proliferation financing became an explicit risk assessment requirement rather than something absorbed into general AML work, and firms are expected to show they have considered it specifically. The indicators differ from laundering typologies, often involving dual-use goods and complex shipping routes. Training staff on what makes PF distinct is what allows your risk assessment to describe something real.

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Tipping Off

Express 10 Minutes Financial Crime For all staff

This is one of the few compliance situations where the natural, helpful response is the illegal one. An employee explaining a delay to an irritated customer can commit an offence with a single sentence. Training staff on what they can and cannot say protects them personally and preserves an investigation that would otherwise be compromised at the counter.

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Customer Due Diligence

Express 10 Minutes Financial Crime For all staff

CDD failures usually happen at the edges: an incomplete file accepted under time pressure, an explanation taken at face value, a change in circumstances never revisited. Staff outside the onboarding team often hold the piece of context that would have raised a question. Making the standard visible across the business is what turns CDD into a control rather than a form.

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Suspicious Activity Reporting

Express 10 Minutes Financial Crime For all staff

Suspicion is a low threshold and the offence is personal, which surprises most people. Reports fail to happen because staff wait for certainty they will never have, or assume someone senior already knows. A short, direct module on the threshold and the route is the most efficient way to correct both assumptions across a whole workforce.

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Unexplained Wealth Orders

Microlearning 5 Minutes Financial Crime For all staff

Unexplained wealth orders allow law enforcement to seize assets if their owners cannot justify their wealth as coming from a legitimate source. This training explores how unexplained wealth orders work, their role in tackling financial crime and the importance of reporting suspicious activity.

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Suspicious Activity Reporting

Microlearning 5 Minutes Financial Crime For all staff

Employees must report any knowledge or suspicion of money laundering or terrorist financing to the Money Laundering Reporting Officer. This training explains reporting obligations, the consequences of failing to report and how to handle suspicious activity appropriately.

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Politically Exposed Persons

Microlearning 5 Minutes Financial Crime For all staff

Politically exposed persons present a high risk of money laundering due to their influence and access to state resources. This training explains how to identify politically exposed persons, assess their risk and apply enhanced due diligence when dealing with them.

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Enhanced Customer Due Diligence

Microlearning 5 Minutes Financial Crime For all staff

Enhanced customer due diligence is required for high-risk customers, including politically exposed persons, high-value transactions and clients from high-risk jurisdictions. This training helps you identify when enhanced customer due diligence is necessary, conduct deeper checks and ensure compliance with regulatory requirements.

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Customer Due Diligence

Microlearning 5 Minutes Financial Crime For all staff

Customer due diligence helps protect us against financial crime by verifying customer identities and understanding their business activities. This training explains initial and ongoing customer due diligence requirements, the importance of knowing your customer and when to report suspicious activity.

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Understanding Terrorist Financing

Microlearning 5 Minutes Financial Crime For all staff

Terrorist groups rely on financial support from various sources, both intentional and unintentional. This training helps employees understand how terrorists secure funds, recognise red flags of terrorist financing and take action to prevent financial crime.

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Terrorist Financing Red Flags

Microlearning 5 Minutes Financial Crime For all staff

Terrorist groups use legal and illegal methods to raise and move funds, often exploiting financial systems to conceal their activities. This training helps you recognise suspicious transactions, high-risk individuals and locations and unusual behaviours that could indicate terrorist financing.

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Preventing Tipping Off

Microlearning 5 Minutes Financial Crime For all staff

Tipping off is a criminal offence that occurs when someone under investigation for financial crime is made aware of the suspicion against them. This training helps employees understand what constitutes tipping off, how to handle customer inquiries without breaching legal obligations and the correct way to respond in these situations.

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The Three Stages of Money Laundering

Microlearning 5 Minutes Financial Crime For all staff

Money laundering is the process criminals use to disguise illicit funds as legitimate income through placement, layering and integration. This training helps employees recognise the stages of money laundering, identify suspicious financial activities and take appropriate action to prevent financial crime.

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Money Laundering Red Flags

Microlearning 5 Minutes Financial Crime For all staff

Detecting and reporting money laundering red flags is essential for maintaining anti-money laundering (AML) compliance. This training helps employees recognise suspicious transactions, assess potential risks and report concerns to the appropriate authorities.

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Understanding Sanctions

Microlearning 5 Minutes Financial Crime For all staff

Sanctions lists change without notice and often at short political notice, which means knowledge dates faster here than in almost any other compliance area. Liability frequently attaches regardless of intent. A short annual refresher keeps staff alert to the fact that yesterday's acceptable counterparty may not be today's, and reinforces the habit of escalating rather than assuming.

Your questions, answered

Financial Crime

How can I log and track incidents of financial crime in my organisation?

Our Compliance Breach Register allows you to securely log and monitor incidents of financial crime, such as bribery or money laundering. The tool enables you to track resolution progress and maintain a clear audit trail, ensuring accountability and compliance with regulatory requirements.

How can I ensure my employees understand and comply with our internal policies in relation to financial crime?

Our Policy Hub enables you to distribute policies such as your Anti-Money Laundering (AML) policy to employees, track acknowledgements, and send automated reminders. This ensures everyone understands their obligations and helps you maintain compliance with financial crime regulations.
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Can small businesses be held accountable under competition law?

Yes. Competition law applies to businesses of all sizes. Even small companies can face investigations and serious penalties for engaging in anti-competitive conduct.

Are informal conversations with competitors risky?

Absolutely. Informal chats, especially those involving prices, market plans, or customers, can constitute unlawful agreements and should be avoided.

What are the consequences of breaking competition law?

Violations can lead to heavy fines for companies, director disqualification, criminal prosecution, and reputational damage.

How can companies prevent anti-competitive behaviour?

By implementing regular compliance training, setting clear internal policies, encouraging reporting of concerns, and ensuring employees understand the legal risks.

Does the Criminal Finances Act 2017 apply to non-UK companies?

Yes. The Act can apply to overseas entities if any part of the tax evasion facilitation occurs within the UK or involves UK tax liabilities. Multinational firms with UK operations should take note.

What industries are most at risk under the Criminal Finances Act?

Industries with complex financial transactions, high-value assets, or extensive third-party relationships such as banking, legal services, real estate, and professional consulting are particularly exposed to conduct and facilitation risks.

How often should businesses review their tax evasion prevention procedures?

Best practice is to conduct reviews annually or whenever there are significant changes in business operations, regulatory guidance, or risk exposure. Regular audits help ensure ongoing compliance.

Can small businesses be prosecuted under the Criminal Finances Act 2017?

Yes. The Act applies to all organisations, regardless of size. However, the HMRC’s guiding principles allow for proportionality, meaning smaller firms are expected to implement controls that match their risk level and operational complexity.

What industries are most vulnerable to proliferation financing risks?

Industries dealing with dual-use goods, advanced technologies, chemicals, and logistics are particularly exposed. Financial institutions supporting international trade also face elevated risks.

How can small businesses ensure compliance with proliferation financing regulations?

Even SMEs should implement basic risk assessments, maintain up-to-date sanctions screening tools, and train staff on red flags related to trade-based money laundering and dual-use items.

Are there international standards for combating proliferation financing?

Yes. The Financial Action Task Force (FATF) provides global guidelines, including Recommendation 7, which focuses on targeted financial sanctions related to proliferation.

What are “dual-use goods” and why are they significant?

Dual-use goods are items that can serve both civilian and military purposes. Their trade is tightly regulated due to the potential for misuse in weapons development.

How often should proliferation financing risk assessments be updated?

Best practice suggests reviewing risk assessments annually or whenever there are significant changes in business operations, customer profiles, or geopolitical developments.

What is an anti-money laundering check?

As per Experian, AML checks “help prevent money laundering by confirming potential customers and businesses are who they say they are, and assessing how likely it is they’re involved in financial crime. For entities regulated by the Financial Conduct Authority (FCA), this due diligence is considered essential and is a legal requirement”.

What is anti-money laundering compliance?

Following AML laws, regulations and procedures to detect and stop suspicious and illicit money flows, including fraud and terrorist financing.

What’s the most common punishment for financial crime?

 Monetary fines: they’re a powerful tool for encouraging 100% compliance. However, financial crime still happens worldwide. For example, cryptocurrency exchange Binance paid a $4.3 billion fine after admitting it engaged in money laundering, among other things. Brazilian engineering giant Odebrecht was fined $2.6 billion for bribery to the tune of £553 million; luxury car and aero-engine manufacturing business Rolls-Royce paid £671 million to settle corruption cases; and global financial services group Barclays received a £284 million fine for failing to control business practices – to name a few.