I am looking to benchmark the triggering events for which other FIs update CDD information for existing customers. Is it limited to the opening of a new account or does it include all instances in which the customer appears in-person (e.g., title change, enrollment in a new service, etc.)? If CDD is updated for title changes, etc., what controls (system, non-system) are used to monitor compliance?

We refresh CDD depending on the risk of the customer. Low Risk customers every 24 months, moderate risk every 18 months and high risk customers every 12 months.

Large activity spikes, significant change(s) in transactional activity, changes in the jurisdictions the customer conducts transactions with and SAR filing(s) are examples of triggering events which could also cause a refresh.

You might also consider a change in business operations or management that the bank becomes aware of, changes in principal signers on an account (not the payroll clerk, but perhaps the CFO, DEO or COO), or a significant change of address (more than adding a PO Box), or symptoms of possible misuse of a shell company as potential triggers.

Great info - we are working on enhancing CDD per an MRA from the OCC - this is helpful in our planning process!