CDD refresh cycles that survive supervisory exams

Periodic CDD refresh often fails quietly. Policies set neat calendars; queues fill with overdue high-risk names while low-risk retail files get polished first.

Start with a living risk register that drives review intervals—not a static spreadsheet. Tie each customer to a risk band, last review date, and trigger events such as ownership change, adverse media, or sudden volume spikes.

Examiners ask who owns overdue cases and how escalation works when capacity slips. Pair queue metrics with sample files so technology and compliance tell one story.

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