Anonymising CDD Onboarding Files for Internal Review – UK GDPR-compliant anonymisation per Money Laundering Regulations 2017

Customer due diligence (CDD) onboarding files aggregate identity documents, proof-of-address records, and risk-rating decisions for each new client. anonym.legal pseudonymises the customer identifiers in these files so compliance teams can audit onboarding quality, benchmark processes, or train staff without exposing individual customers' personal data during internal review.

When this applies

This task applies when CDD onboarding files are circulated to internal audit, compliance oversight teams, or training facilitators who require sight of the procedural quality and risk-rating rationale but have no legitimate need to process the named customers' personal data.

  1. Upload the CDD onboarding pack (PDF or DOCX) to anonym.legal; document structure and formatting are preserved.
  2. The engine detects personal-data entities across 285+ categories — full names, dates of birth, addresses, national insurance numbers, passport references, and contact details of the customer and any associated beneficial owners.
  3. Each customer and associated individual is assigned a consistent pseudonym applied uniformly across the onboarding checklist, identity verification notes, and risk-rating decision record.
  4. Risk-rating outcomes, onboarding-stage timestamps, source-of-funds category, and procedural checklists remain in clear text.
  5. A reversible mapping table is generated with UK/EU data residency, enabling full re-identification by the originating compliance team.
  6. Release the pseudonymised pack for internal audit or training; use the mapping key to restore original identities when the file is required for regulatory inspection.

What you provide

  • CDD onboarding checklist and decision record
  • Identity verification notes (names, document types, verification outcome)
  • Risk-rating rationale document

Limitations & cautions

  • The pseudonymised pack is for internal review only; any regulatory production of CDD records must use the re-identified originals.
  • Scanned identity documents with low image quality may require OCR pre-processing for full entity detection.
  • The tool pseudonymises personal data but does not assess whether the CDD procedure meets the standard required by the Money Laundering Regulations 2017.

FAQ

Can I use pseudonymised CDD files for staff AML training?

Yes. Pseudonymised onboarding packs that preserve the procedural and risk-rating narrative are ideal for training purposes, removing the risk of unnecessary personal-data processing by trainees.

Does the engine detect non-UK identity document references?

Yes. The engine covers international identity document formats. Passport numbers, national identity card references, and similar identifiers are detected irrespective of issuing country.

What happens to the risk-rating score in the pseudonymised file?

Risk scores, risk categories, and the procedural rationale are preserved in clear text. Only the customer's identifying information is pseudonymised.

Is the mapping table stored in the UK?

All processing and storage occurs within UK/EU data residency boundaries in line with UK GDPR requirements.

Financial Services Compliance

About this page

We update this page when our platform or the law changes.

Read our founder note for how we work.

Each change shows up in the timestamp at the top.

We follow these rules

  • GDPR (EU 2016/679).
  • ISO/IEC 27001:2022.
  • NIS2 (EU 2022/2555).
  • HIPAA safe harbor under 45 CFR § 164.514(b)(2).

Our promise

We do not sell your data.

We do not train models on your text.

We store your files in Germany.

You can delete your account at any time.

You own your work.

Where we run

Our servers live in Falkenstein, Germany.

We use Hetzner. They hold ISO 27001 certification.

All data stays in the EU.

Backups run every day.

Need help?

Email support@anonym.legal.

We reply within one business day.

How we test

We run a full check suite on every release.

Each surface gets its own sweep script and report.

Human reviewers spot-check the output each week.

We track recall and precision on a labelled set.

Bad runs block the deploy.

What we never do

  • We never sell your information to third parties.
  • We never train models on what you upload.
  • We never keep your work after you delete it.
  • We never share keys with any outside firm.
  • We never run ads inside the product.

Plans in plain words

We sell credits, not seats.

One credit covers one short job.

Long jobs use a few credits each.

You can top up at any time.

Unused credits roll over each month.

Read the plans page for current rates.

Who built this

A small team of engineers and lawyers built this.

We ship from Europe and work in the open.

Our founder note spells out why we started.

Where to start

How the parts fit

A browser add-on cleans text inside Chrome.

A Word plug-in handles drafts in Office.

A small desktop tool works on whole folders.

An agent protocol link feeds large models safely.

All four share one core engine and one rule set.

Words from our team

We started this work after a lunch about cookies.

One friend kept getting odd ads on her phone.

We asked why a court file leaked through a draft.

We sketched the first build on a napkin that week.

By month three we had a tiny demo for a friend.

She used it on her first case the next day.

Common questions we hear

Can the tool read scanned PDFs? Yes, with OCR.

Does it work on long files? Yes, in small chunks.

Can I roll my own rule set? Yes, save it as a preset.

Does it run offline? The desktop build runs offline.

Do you keep my files? No, the cloud build wipes after each run.

Will it learn from my work? No, we never train on inputs.

A short tour of the workflow

Upload a file or paste a snippet of prose.

Pick the entities you want gone from the draft.

Choose a method: replace, mask, hash, encrypt, or redact.

Press run and watch the side panel show each hit.

Skim the result and tweak any rule that misfired.

Save the cleaned file or send it to a teammate.