LinkedIn·Thursday, 13 August 2026·13d ago

The dangerous thing about a weak EDD? The consequences may arrive 15 years later ⁉️ In the recent Lombard Odier Group AML case involving…

Lukasz Lukaszewski

CPO @ ChainComply - Decision Layer for Crypto-related EDD

The dangerous thing about a weak EDD? The consequences may arrive 15 years later ⁉️ In the recent Lombard Odier Group AML case involving more than $120 million in incoming funds, the transactions at the centre of the case took place in 2011 and 2012. The judgment with a CHF 3 million fine came in July 2026, so 15 years later. According to the Swiss Federal Criminal Court, the relationship manager was aware of evidence suggesting corruption, but within EDD settled for superficial checks and failed to establish the origin and economic #SourceOfWealth. There is an important compliance lesson here: - Your EDD decision may be examined 10 or 15 years after you made it. - By then, the relationship manager may be gone. The compliance officer may be gone. - People will not remember why a decision seemed reasonable. - In the future, the amount of fines can be significantly higher than 2.5% (⁉️) of the money laundered - What remains is the evidence, the analysis and the documented conclusion. And this matters enormously for the EDD in crypto, where in many cases the Source of Funds / Source of Wealth checks are the only way to decide on the transaction. Meanwhile, today, even in multi-million-dollar cases, companies scan a wallet against sanctions, mixers, darknet exposure and make decisions in seconds. But could someone open this file in 2040 and understand why you approved the client?