Reviewing and updating Customer Due Diligence (CDD) Information
The review and update of Customer Due Diligence (CDD) information form a core part of an effective AML/CFT risk management framework.
As mandated under the UAE AML-CFT Decision, all Reporting Entities are required to maintain accurate and up-to-date customer and beneficial ownership records.
Why it matters:
Accurate CDD data enables reporting entities to correctly assess customer risk levels and detect potential Money Laundering (ML) or Terrorist Financing (TF) concerns in a timely manner.
Outdated or incomplete information increases exposure to compliance breaches and reputational risks.
Key expectations under the regulation:
- Risk-based frequency of review: High-risk customers must undergo more frequent CDD updates, while low-risk customers can be reviewed at longer intervals, provided no ML/FT suspicion arises.
- Periodic and event-driven reviews: Policies should clearly define the timing, frequency, and triggers for both scheduled and event-driven reviews — such as changes in ownership, discovery of adversen information, or the expiration of key identification documents.
- Defined review scope: Procedures should outline the extent of review activities, including when to verify the source of wealth/funds, review transaction history, or revalidate the purpose of the business relationship.
- Organisational accountability: Responsibilities must be clearly assigned — from performing reviews, escalating reclassifications, and obtaining senior management approvals (especially for PEPs), to ensuring record-keeping and internal audits of the review process.
At Young Global, we help Reporting Entities design, implement, and strengthen CDD review frameworks tailored to their business size and risk exposure.
Our AML specialists ensure your internal policies and procedures are fully aligned with UAE’s regulatory requirements — enhancing both compliance and operational efficiency.
Contact us today:📱 055 689 0505 📧 [email protected]
Strengthen your AML framework — keep your CDD data current, compliant, and audit-ready
