TABLE OF CONTENTS

Overview


A CDD refresh alert tells you it's time to re-verify a customer you've worked with before. When the alert is due, you create a new case from it, confirm whether anything important has changed, and complete due diligence again so the record stays current.


Refresh alerts appear in the Alerts section of the platform. When you action one, the platform creates a new case, pulls through all the information from the previous case (including any previously verified individuals), and tags it as a CDD refresh case so it's easy to identify.


The steps you follow depend on what you're refreshing:


  • Refreshing an entity (a company, trust, or other legal entity with an ownership structure): follow every step, from Step 1 to Step 6.
  • Refreshing an individual (a single person, with no structure to check): follow Step 1, then skip to Step 5 and continue to the end.


Each section below states whether it applies to entity cases, individual cases, or both.

Step 1: Create the case from the alert


Applies to: all cases

  1. Go to the Alerts section.
  2. Find the relevant CDD refresh alert for your client.
  3. Click Create case.


The platform creates a new case for that entity or individual. It pulls through all the information from the previous case, including any previously verified individuals, and tags the new case as a CDD refresh case.


Now choose your path. Refreshing an entity? Continue to Step 2. Refreshing an individual? Skip to Step 5.


For entity cases: review and refresh the structure

Steps 2 to 4 only apply to entity cases. They check whether the ownership structure has changed since it was last verified.


Refreshing an individual? Skip this whole section and go to Step 5.


Step 2: Run a fresh unwrap


Applies to: entity cases

Run a fresh unwrap only if you want to check for changes to the ownership structure since the original verification.


  1. On the Structure page, remove the existing entries, keeping only the root entity.
  2. Save your changes.
  3. Click Start unwrap.
  4. Wait for the platform to finish.


A fresh unwrap pulls current data from the registries and identifies any structural changes, such as new directors or removed shareholders, since the original verification.


If you don't run a fresh unwrap, skip Steps 3 and 4 and go to Step 5.


Step 3: Compare the old and new structure


Applies to: entity cases

Once the unwrap has finished:

  1. Open the original case to see the structure as it was first verified.
  2. Compare it with the newly unwrapped structure in your refresh case.
  3. Identify any individuals who are new, and any who were already on the case.


The fresh unwrap pulls through individuals again from the registry. Some of these are genuinely new. Others are people who were already on the case, because they were pulled through from the previous case when the refresh alert was actioned. That means you can end up with two versions of the same individual: the previously verified version, and a fresh, unverified version from the unwrap. Step 4 sorts this out.


Step 4: Tidy up the individuals after the unwrap

Applies to: entity cases where you ran a fresh unwrap


Work through the individuals the unwrap returned. There are two situations to handle.


New individuals (not on the original case)


These people were identified by the fresh unwrap and weren't part of the previous verification. They have no verified information yet. Confirm each one belongs on the case. You'll verify them at Step 5.


Duplicate individuals (already on the case)


These people were pulled through from the previous case when the alert was actioned, and then pulled through again by the fresh unwrap. You now have a previously verified version and a fresh, unverified version. Keep the verified one and remove the duplicate:


  1. Delete the newly unwrapped version of the individual from the structure.
  2. Add the existing version of the individual (the one still on the case, which holds all the previously verified information) into the refresh structure.
  3. Apply the correct tags so that only one version of that individual remains.


All cases: complete the refresh


Individual refreshes pick up here, straight after Step 1. Entity refreshes continue from Step 4.


Step 5: Complete the standard case steps


Applies to: all cases

  1. Verify any new individuals that require verification under your compliance programme.
  2. Complete verification of any new entities in the structure, if required.
  3. Complete the risk assessment, if required.
  4. Complete the case as per your standard process.


Step 6: Mark the case complete and track the next refresh


Applies to: all cases

  1. Make sure each individual and entity is marked as a pass. Marking a pass assigns a last verified date.
  2. Mark the case as Completed.
  3. The new risk level sets the next refresh cycle. If the risk level has changed, the next alert is based on the new cycle.


Example: a client who was originally low risk (a 24-month cycle) but is now medium risk (an 18-month cycle) will have their next alert triggered on the medium-risk timeline.