Compliance

Enhanced due diligence (EDD): deeper than KYC when the risk is high

Enhanced due diligence (EDD) is an in-depth check of a higher-risk player: large amounts, PEPs, high-risk countries, unusual transactions. The operator requests proof of the source of funds and source of wealth, bank statements, and then monitors the player more closely.

Yevhen SychovOctober 2026

When it is needed

Every player goes through standard KYC. Enhanced due diligence is triggered by high risk, and what counts as high risk is set out in the operator's AML policy:

  • Large amounts: deposits over a period above the policy threshold.
  • PEP: a politically exposed person, their family and close associates.
  • High-risk country: the player's citizenship, address or bank is in a country on the policy list.
  • Unusual transactions: amounts that do not fit the profile, deposits and withdrawals with almost no bets, third-party payment methods.

What is requested

  • Source of funds: where this particular money comes from, for example a salary, the sale of property or dividends.
  • Source of wealth: how the player built their wealth as a whole.
  • Evidence: several months of bank statements, proof of income, a sale agreement.

After the check, the player is monitored more closely: lower alert thresholds and regular profile reviews. Working with a PEP also needs senior management approval. The requirements depend on the licence.

Threshold and example

EDD trigger: total deposits over 30 days above the policy thresholdFor example, the threshold is €20,000 over 30 days. The player deposited €8,000, €7,000 and €6,000: €21,000 in total, so the threshold is crossed. The manager warned the player right after the second deposit, at €15,000, and the documents were already gathered by the time the threshold was reached.

Each market and operator sets its own threshold and window. The system works out when the trigger fires, so the check does not depend on a manager's mood.

How not to lose a VIP

  • Explain in advance: it is a licence requirement, not a personal suspicion of the player.
  • The full list at once: in a single message, with the document formats and how long the check takes.
  • Get through it fast: the VIP manager guides the player personally, and the check status is visible in the player's account.
  • No deposit offers until the check is complete.

Common mistakes

  • Checking at the moment of withdrawal. A high roller learns about EDD while waiting for a big win to be paid out and decides the casino does not want to pay.
  • Documents one at a time. A bank statement today, proof of income a week later, a contract a week after that: the check drags on for a month, and the player leaves.
  • The decision is not recorded. The documents were received, but there is no record of who checked them, what was decided and when the next review is due. As far as the regulator is concerned, the check never happened.
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