What is the difference between the CDD role and the front-line staff role?
Transaction sign-off authority: CDD User can formally complete and sign off transactions, while Frontline Staff can initiate KYC requests but must always escalate for sign-off.
The decisive difference is transaction sign-off authority. CDD User can formally complete and sign off on a transaction - which is the legal act of confirming the firm's CDD obligations have been met for that customer / matter. Frontline Staff cannot sign off transactions - they can initiate KYC requests and request the customer-facing data collection, but the sign-off step always escalates.
What this means in practice:
- Capability: Initiate KYC / KYB requests; Frontline: ✓; CDD User: ✓
- Capability: Send VOI links to customers; Frontline: ✓; CDD User: ✓
- Capability: See KYC completion status; Frontline: ✓; CDD User: ✓
- Capability: View completed ID document images; Frontline: x; CDD User: ✓
- Capability: View detailed PEP / sanctions output; Frontline: x; CDD User: ✓
- Capability: Sign off a transaction; Frontline: x; CDD User: ✓
- Capability: Escalate risk rating; Frontline: x; CDD User: ✓
- Capability: Add notes to the audit trail; Frontline: ✓; CDD User: ✓
If a firm assigns Frontline Staff only, the CO (or another CDD-or-above user) must be the one signing off every transaction. For high-volume offices this becomes a bottleneck - which is why most firms with structured teams assign CDD User to senior practitioners.
Practice varies by firm. Smaller firms often have everyone as CDD User (or CO if sole-trader); larger firms separate the data collection function (Frontline) from the sign-off function (CDD User).