Field Notes · Tue Feb 03 2026 19:00:00 GMT-0500 (Eastern Standard Time)
CDD Files That Survive Sampling
What distinguishes a customer due diligence file that holds up under sample testing from one that collapses in the first hour.
A CDD file is not a checklist with ticks. It is a short story proving you knew who you onboarded and why the risk rating fits. When we sample for fintech AML assessments, files fail for predictable reasons: screenshots without dates, beneficial ownership charts that stop at a holding company, and risk ratings that never change after a product upgrade.
The three artifacts that matter
First, a dated identity verification record that matches the legal name on the account. Second, a purpose-of-account note written in plain language — “payroll for 40 retail staff” beats “business use.” Third, evidence that periodic review actually happened, not merely that a calendar invite existed.
When high-risk clients need more
High-risk merchants and cross-border remitters require source-of-funds trails that a second reviewer can follow without calling the relationship manager. If your file depends on oral knowledge held by one person, the sample will fail the moment that person is on leave.
Build files as if the sampler has never met your firm. That habit alone removes half the findings we typically raise in AML program assessments for fintech operators.