Common CDD File Review Mistakes

Self-auditing is the best way to prepare for external regulatory exams. Here are the top three mistakes found in CDD files globally:

1. Expired Identification

Often, identity documents are valid at the time of onboarding but expire without a refresh process being triggered.

2. Poor UBO Mapping

Complexity often hides ownership. Failing to map out the full tree back to a natural person (or a listed entity) is a major red flag.

3. Missing "Purpose of Account"

Generic statements like 'business use' are insufficient. What specific types of transactions are expected?