THE COMPASS DIRECTION | Know the Expected Pattern
What should we know about a customer’s expected activity, and when should we update that information?
Customer due diligence that helps the next review
A useful customer/member profile explains the nature and purpose of the relationship. Collect and update information on a risk basis—not merely to fill every possible field.
| COMPASS CHECK | YOUR DIRECTION: PRACTICAL QUESTIONS |
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| PURPOSE | Why is this account needed? What does the business do, or what activity is expected for the individual? |
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| FUNDING | What sources normally fund the account? Consider expected cash, payroll, checks, ACH, and wires as relevant. |
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| MOVEMENT | What transaction volumes, ranges, counterparties, and geographic connections fit the relationship? |
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| CHANGE | Has actual activity materially changed? Assess new facts and update customer information and risk treatment as appropriate. |
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| FOLLOW-THROUGH | Make relevant information available to authorized reviewers. A refreshed profile should inform monitoring, not sit unused. |
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FYI EXAMPLE: A local retailer begins receiving payments inconsistent with the recorded business model. Seek a reasonable explanation and relevant support; assess whether the profile or investigation needs updating.
POINT NORTH: Risk-based review is not a universal annual refresh mandate. Follow event-driven triggers and institution procedures.
Source: FFIEC, Customer Due Diligence; 31 CFR 1020.210(b)(5). This poster does not prescribe beneficial-ownership collection exceptions or account-opening rules.
Training aid • October 20, 2026 • Compliance review before use; current rules and institution procedures control.
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