Ongoing Monitoring Is CDD in Motion
Explain how CDD profiles support ongoing monitoring and suspicious activity escalation.
The reframe: An alert is a question about fit, not just a threshold breach. Capture expected activity Good CDD describes the customer's ordinary money story: business model, source of funds, counterparties, geographies, products, channels, and likely transaction range. The goal is not prediction to the dollar. The goal is enough context to evaluate later behavior. Compare observed behavior When monitoring fires, compare the alert to the baseline. Is the activity consistent with the stated purpose? Has the customer changed business lines? Is there an invoice, contract, payroll cycle, or seasonal reason? If not, the risk question remains open. Update or…
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