CDD: When to Review a Customer Relationship
A key component of any BSA Program is customer due diligence. Essentially, institutions need to have a finger on the pulse of customer activity. “How” that gets accomplished and who does it is likely going to differ from institution to institution, but lenders play a key role because they often know their customers better than anyone else. Institutions need to have policies, procedures and processes in place to help determine when the risk associated with a customer relationship appears to be changing or has already changed. Below are a few examples of when a review of a customer relationship might be warranted:
- Significant and unexplained changes in account activity or payment activity
- Changes in employment or business operation
- Changes in ownership of a business entity
- Red flags identified through suspicious activity monitoring
- Receipt of law enforcement inquiries and requests
- Results of negative media search programs
- Length of time since customer information was gathered and the profile was assessed
Kevin explains more in the video.
Published 2026/02/17
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).