Customer Due Diligence (CDD) is the process of identifying a client, verifying their identity, and understanding their financial circumstances and risk profile.
“Ongoing” CDD means that this understanding must be maintained over time. It is not a one-off exercise.
In practice, this means:
- updating your understanding when circumstances change
- reassessing risk when new information emerges
- ensuring transactions remain consistent with the client profile
Ongoing CDD is closely linked to monitoring. If behaviour changes, your understanding must also change.