I'm a little confused by what CDD procedures should be followed so I would like to know what other banks are doing. We have not implemented risk rating procedures for customers so we'll be starting from the bottom. I want to make sure that we're doing what is best practices.

I was also wondering what other Banks are doing for CDD. We currently have a risk rating format for our business customers, but nothing for our personal customers.

The manual states that CDD must be conducted on all customers. Does this mean going backwards, of all our customers in the database, or going forward from a date?

I'm very confused.

We're actually doing that now and we're starting with our commercial accounts first since the risk is higher and then doing the rest of the customer database.

Funny, but this just came up with our bank as well. We are currently working on a revised risk rating format and this time we will include all customers not only business.

We will work from this time forward, however, eventually, we will go back on all commercial accounts.....