AML due diligence generally refers to the process of identifying customers to ensure that they do not pose risks for money laundering or other criminal activity. The CFTC advises that a “due diligence program must ensure, at a minimum, that [a] financial institution takes reasonable steps to ascertain the identity of the nominal and beneficial owners of [a] private account, whether any such person is a senior foreign political figure, the sources of funds deposited into the private banking account and the purpose and expected use of the account.” The CFTC also advises that “enhanced” due diligence efforts will be required in various circumstances.