cdd-risk-review

Quality-reviews a customer due diligence file (new account, periodic refresh, or event-driven refresh) against the four CDD pillars and named CDD examination expectations. Reads customer identification, beneficial ownership identification and verification, the nature-and-purpose / expected-activity profile, the customer risk rating and its drivers, and the ongoing-monitoring trigger set; produces a second-line review memo with material gaps, evidence-needed items, EDD-trigger posture, and recommended decision checkpoints with named owners. Does not approve onboarding, set or change the customer risk rating, file a SAR, or close or exit the relationship.