Typical gaps include:
– Missing or outdated KYC documentation
– Weak identification and verification of UBOs
– Incomplete or outdated risk assessments
– Limited evidence of ongoing monitoring
CDD is not a one-off exercise.
It must be current, complete, and continuously reviewed to withstand regulatory scrutiny.
At Acrion, we help firms strengthen CDD frameworks that are practical, risk-based and inspection-ready.
Navigating Compliance. Managing Risk. Differently
