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Q.

When must Customer Due Diligence CDD be Conducted?

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Summary
Customer due diligence (CDD) must be conducted when establishing a business relationship or opening an account with a customer. It is also required when carrying out occasional transactions above the prescribed threshold, when money laundering or terrorist financing is suspected, and when doubts arise about previously obtained customer identification data. Ongoing CDD is further required throughout the relationship, particularly when the customer's risk profile or transaction pattern changes.

Customer due diligence (CDD) is required at the start of a business relationship or when an account is opened. It must also be performed for occasional transactions exceeding the set threshold, when there is suspicion of money laundering or terrorist financing, and when the accuracy of earlier customer identification data is questionable. Continued CDD applies during the relationship as well, especially if the customer's risk profile or transaction behavior shifts. Below, I have shared when must customer due diligence cdd be conducted.

What are the Situations that Require CDD?

  • Account Opening: Verify identity and address using officially valid documents before establishing any account-based relationship.

  • Occasional Transactions: Run checks on one-off transactions above the prescribed threshold, including linked transactions that together cross the limit.

  • Wire Transfers: Confirm originator and beneficiary details for transfers exceeding the specified amount.

  • Suspicion Arises: Apply checks whenever money laundering or terrorist financing is suspected, irrespective of exemptions or thresholds.

  • Doubts about Data: Repeat verification when earlier identification data appears false, outdated, or inadequate.

  • Risk Profile Changes: Refresh checks when the customer's activity, ownership, or risk category shifts noticeably.

  • New Products or Services: Reassess the customer when they apply for a higher-risk facility, such as a large credit line or foreign remittance service.

  • Periodic Review: Update records at regular intervals, more frequently for high-risk customers than for low-risk ones.

What Information do Institutions Collect during CDD?

Institutions collect the customer's full name, photograph, permanent address, PAN, and other officially valid identity proofs. For companies, trusts, and partnerships, they also identify beneficial owners, directors, and authorized signatories. The customer's occupation, income source, and intended account activity are recorded to build a risk profile. Higher-risk customers may face additional questions about their funds and business relationships, and all collected records are retained for the period prescribed by law.

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