What is Ongoing Due Diligence?

Identity & compliance
Ongoing review & funding context
3 min read

The short answer

Ongoing due diligence maintains an understanding of an existing relationship as customer information and activity change.

Ongoing Due Diligence: why it matters

An onboarding or review decision can contain several different questions. Keeping this concept distinct helps the team assign the right evidence and decision owner, rather than rely on a single completed status.

How to assess it in practice

Define which changes trigger reassessment and ensure that review outcomes update the retained customer file. Start by defining the question the team needs to answer. Identify the relevant record or evidence, check its scope and date, and retain the reasoning behind the result. If evidence conflicts, keep that conflict visible for review.

Worked example

Illustrative workflow: a team reviewing a business adds a separate check for ongoing due diligence. The reviewer’s task is to define which changes trigger reassessment and ensure that review outcomes update the retained customer file. The outcome is recorded together with the supporting evidence; an unresolved question stays open rather than being converted into a positive result.

Illustrative scenario

An ownership alert arrives after onboarding. The case remains open until someone assesses whether the new owner changes the relationship's risk or evidence requirements.

Distinctions that matter

Ongoing Due Diligence belongs to the ongoing review & funding context topic family. Read Periodic Review alongside it to understand the adjacent question. Each page has its own intended scope; shared context does not make the concepts equivalent.

Evidence and review output

Review these

Previously approved baseline
New facts and source dates
Review outcome and next trigger

The review should produce

An updated relationship assessment with changes, unanswered questions and the next action made explicit.

Across this family

Compare the current understanding of a relationship with its approved baseline. A scheduled review and an event-driven review can answer different questions, so specify what triggers each and how outcomes update the file. A delivered notification is not itself a completed reassessment.

A note from practice

Ongoing review needs a feedback loop from changes to decisions. A monitoring alert is only an input; define how it updates the customer file, who assesses it and what closes the review.

Limits and common mistakes

The practical boundary is important: Define which changes trigger reassessment and ensure that review outcomes update the retained customer file. Do not substitute a related label for this check or assume that missing information is a negative finding. Source-specific and jurisdiction-specific rules require their own review.

Frequently asked questions

Which evidence should I review?

For this topic, focus on previously approved baseline, new facts and source dates, review outcome and next trigger. The relevant source and dates should be retained with the finding.

How is Ongoing Due Diligence different from Periodic Review?

Periodic review reassesses a relationship on a defined schedule using relevant current information. The distinction matters because the evidence needed for that concept may not resolve the question addressed on this page.

What should the result of the review contain?

An updated relationship assessment with changes, unanswered questions and the next action made explicit. Preserve material conflicts instead of replacing them with an unexplained success flag.

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