A KYC analyst is performing EDD on a customer because of a deviation in expected transaction activity. Which factor should the analyst keep in mind if contacting the customer as part of this due diligence?

The prohibition against "tipping off" is a fundamental principle in anti-money laundering (AML) and counter-financing of terrorism (CFT) compliance. When an analyst contacts a customer to inquire about unusual activity as part of Enhanced Due Diligence (EDD), the primary concern is to gather legitimate information without alerting the customer that they are under suspicion. Tipping off a customer could compromise an ongoing or future investigation by law enforcement, lead the customer to move illicit funds, or destroy evidence. Therefore, all communication must be handled with extreme care to avoid any indication that the customer's activity is being scrutinized for potential illicit conduct.

B. This is incorrect. KYC analysts are often trained and authorized to conduct customer outreach as part of their due diligence responsibilities, operating under the institution's established policies and procedures.
C. This is misleading. The focus should be on the business or transactional rationale, not the internal "due diligence" process, as discussing the latter could easily lead to tipping off.
D. This is a general security best practice, not the primary AML-specific legal or regulatory principle governing the content and purpose of the customer communication during an investigation.

1. ACAMS Certified Know Your Customer Associate (CKYCA) Study Guide

Chapter 4: Conducting and Documenting Ongoing Monitoring. The guide emphasizes that when conducting EDD and investigating alerts

analysts must be careful not to tip off the customer. The objective is to obtain a reasonable explanation for the activity without revealing the institution's underlying suspicion.

2. Financial Action Task Force (FATF)

The FATF Recommendations: International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation (Updated October 2023). Recommendation 21

"Tipping-Off and Confidentiality

" explicitly states that financial institutions and their employees are prohibited from disclosing the fact that a suspicious transaction report (STR) or related information is being filed or provided to the financial intelligence unit (FIU). This principle extends to inquiries that would lead a customer to infer such an action.

3. The Wolfsberg Group

Statement on Effectiveness: Demonstrating the Effectiveness of an Anti-Money Laundering / Counter Terrorist Financing (AML/CTF) Programme (June 2019). Section 3.2

"Investigation

" implicitly supports this by highlighting the need for skilled investigators who can manage sensitive inquiries. Effective investigation includes gathering information

often through customer contact

in a manner that does not compromise the integrity of the AML/CTF framework

which includes the prohibition on tipping-off.