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A Due Diligence Policy outlines the steps your organization takes to evaluate risks and verify facts before making important business decisions. It's a crucial framework that helps Irish companies comply with regulations like the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 while protecting themselves from potential legal and financial problems.

The policy typically covers key areas like customer screening, transaction monitoring, and background checks on business partners. It guides staff through essential verification processes, sets clear responsibilities, and creates an audit trail to show regulators that your company takes its compliance duties seriously. For regulated sectors in Ireland, having this policy isn't just good practice - it's often a legal requirement.

You need a Due Diligence Policy when your business starts engaging with new clients, partners, or suppliers in Ireland. It's especially crucial for financial services, property transactions, and any business activities that fall under Irish anti-money laundering regulations. Put this policy in place before you begin onboarding customers or entering significant business relationships.

The policy becomes essential when expanding into new markets, acquiring companies, or handling large financial transactions. Irish regulators expect to see it during compliance audits, particularly in regulated sectors. It's also vital when your business faces increased scrutiny from stakeholders, or when you're dealing with high-risk clients or jurisdictions that require enhanced verification procedures.

• Standard Customer Due Diligence: Basic policy covering routine client verification, focusing on identity checks and risk assessment for typical business relationships
• Enhanced Due Diligence Policy: More rigorous framework for high-risk clients or politically exposed persons, requiring deeper investigation and ongoing monitoring
• Merger & Acquisition Due Diligence: Specialized policy for corporate transactions, covering financial, legal, and operational assessments
• Supply Chain Due Diligence: Focuses on vendor verification, modern slavery compliance, and supply chain risk management
• Anti-Money Laundering Due Diligence: Detailed procedures aligned with Irish AML regulations, including transaction monitoring and suspicious activity reporting

• Legal Counsel: Draft and review Due Diligence Policies to ensure compliance with Irish regulations and corporate requirements
• Compliance Officers: Implement and oversee the policy's day-to-day operation, train staff, and maintain documentation
• Board of Directors: Approve the policy and ensure adequate resources for its implementation
• Risk Management Teams: Use the policy to assess and monitor business relationships and transactions
• Front-line Staff: Follow policy procedures when onboarding clients or engaging with business partners
• External Auditors: Review policy implementation and effectiveness during compliance assessments

• Risk Assessment: Map your organization's risk areas and regulatory obligations under Irish law
• Industry Research: Review sector-specific requirements and Central Bank of Ireland guidelines
• Process Review: Document your current verification procedures and identify gaps
• Stakeholder Input: Gather feedback from compliance, legal, and operations teams
• Technology Check: Evaluate your systems' capability to support policy requirements
• Training Plan: Outline how staff will learn and implement the new procedures
• Review Mechanism: Define how often the policy needs updating and who's responsible

• Purpose Statement: Clear objectives and scope of due diligence activities under Irish law
• Risk Assessment Framework: Methodology for evaluating client and transaction risks
• Verification Procedures: Specific steps for identity checks and document validation
• Data Protection Measures: Compliance with GDPR and Irish Data Protection Act 2018
• Reporting Requirements: Procedures for suspicious activity reporting to relevant authorities
• Record Keeping: Document retention periods and storage requirements
• Staff Responsibilities: Clear assignment of roles and accountability
• Review Process: Timeline and procedure for policy updates

A Due Diligence Policy differs significantly from a Due Diligence Checklist in both scope and function. While they work together, each serves a distinct purpose in your organization's compliance framework.

• Framework vs. Tool: The policy establishes your overall approach and principles for conducting due diligence, while the checklist is a practical tool listing specific items to verify
• Permanence: The policy is a standing document that guides long-term operations, whereas checklists are typically transaction-specific and disposable after use
• Audience: Policies inform all stakeholders about procedures and responsibilities, while checklists primarily serve as working documents for staff conducting investigations
• Legal Weight: Your policy carries more formal authority and is often required by Irish regulators, but checklists mainly serve as evidence that due diligence was properly performed