Customer Due Diligence Review

Periodic review of existing customer relationships for updated risk assessment and ongoing due diligence. Required by 31 CFR 1010.230. Takes 30-45 minutes per review. Best for: BSA analysts, relationship managers.

3 steps

Banking

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Process steps

Review account activity since last review

3 days from previous step

task

Pull transaction history since the last due diligence review. Look for changes in patterns: volume, geography, counterparties. Compare actual activity to expected activity documented at account opening or last review. Flag significant deviations.

Form fields in this step

Activity Consistent with Expected *

Transaction Volume *

Notable Patterns

Verify current customer information

5 days from previous step

task

Confirm customer contact information is current. For businesses, check that beneficial ownership information is still accurate. Request updated documentation if anything has changed. Per FinCEN guidance, beneficial ownership must be updated for any triggering event.

Form fields in this step

Contact Info Current *

Beneficial Ownership Current (Business)

Update risk rating and document review

7 days from previous step

task

Based on your review, confirm or update the customer's risk rating. Document your analysis, any concerns, and the basis for your rating. Schedule the next review based on the risk level. File the completed review in the customer's CDD file.

Form fields in this step

Updated Risk Rating *

Rating Changed *

Next Review Date *