Which of the following is not typically collected under Customer Due Diligence?

• A. Beneficial Ownership
• B. Business or Occupation
• C. Employee payroll records
• D. Source of funds

Answer: (C)

Customer due diligence is about confirming who the customer is and understanding the level of risk they present. You gather details that reveal the customer’s identity and control structure, their typical activities, and where their funds originate. Beneficial ownership is collected to see who ultimately owns or controls the customer, helping uncover hidden ownership and potential control by sanctioned or high-risk individuals. The nature of the customer’s business or their occupation helps gauge likely transaction patterns and risk level. Source of funds is checked to ensure the money being brought in isn’t from illicit or high-risk sources.

Employee payroll records, however, pertain to the customer’s internal payroll and their own employees, not to the customer’s identity, ownership, or typical transactions. They don’t illuminate how the customer is funded or who ultimately controls the customer, and they raise privacy concerns. Therefore, payroll records are not part of standard Customer Due Diligence.