Ongoing Due Diligence

Ongoing due diligence is the requirement that a firm keeps knowing its client after onboarding, rather than checking once and filing the result. It has two halves: keeping the record current — identity documents that expire, an address that changes, a declaration that is no longer true — and monitoring activity against what the account said about itself when it opened. This is why document requests arrive years into a relationship with nothing apparently prompting them. A periodic refresh is scheduled by the firm's own risk rating for the account, so a request is usually a calendar event rather than a reaction to something. Activity monitoring is the other half and works differently: it compares funding and trading against the stated occupation, income and purpose, so a change on the client's side that was never notified reads as a mismatch. Both halves are backed by the same lever, which is that continued access can be restricted until the file is current — the reason an out-of-date document is worth replacing before it is asked about rather than after.