Ongoing Due Diligence (ODD) is the continuous process of monitoring and reviewing customer relationships to ensure that the information collected during initial onboarding remains accurate, up to date and relevant over time. It is a core component of effective Know Your Customer (KYC) and Anti-Money Laundering (AML) Compliance programs, allowing financial institutions and regulated entities to detect changes in customer behavior, Risk Profiles or Ownership Structures that may signal potential Financial Crime.
Unlike Customer Due Diligence (CDD), which occurs at the start of a business relationship, Ongoing Due Diligence is performed throughout the lifecycle of the relationship. It includes regular transaction monitoring, periodic Risk Profile reviews, Screening against Screenings and Watchlists, and updating documentation such as ownership records, proof of address or identification. The goal is to ensure that the business relationship continues to align with regulatory expectations and the institution’s internal risk tolerance.
Ongoing Due Diligence is especially critical for high-risk customers, Politically Exposed Persons (PEPs) or entities operating in High Risk Jurisdictions, where changes may present increased exposure to Money Laundering, Fraud or Terrorist Financing. By implementing robust ODD practices, organizations can strengthen Compliance, reduce regulatory penalties and demonstrate a proactive approach to financial crime prevention.