Field Notes · 2 April 2026
Building a CDD refresh calendar that survives sampling
Practical calendar design for customer due diligence refresh cycles in remittance and e-payment firms facing periodic AML evidence reviews.
Customer due diligence refresh work often lives in a spreadsheet someone updates after hours. That arrangement fails the moment an AML evidence review asks for a population of accounts due in a given quarter and the evidence that refreshes actually occurred.
Anchor refresh dates to risk ratings you can defend
If your risk model changes mid-year, document the bridge. Auditors will ask why a medium-risk merchant moved to high risk without a refresh trigger.
Capture incomplete refreshes honestly
A half-finished pack with a dated chase log is stronger than a green status with no file. Examiners notice invented completeness.
Connect the calendar to onboarding spikes
Fintech marketing campaigns create onboarding waves; refresh debt follows months later. Capacity planning for analysts should mirror those waves, not a flat monthly average.
Teams preparing an AML evidence review with Tidewater should expect sampling from the calendar itself, not only from closed cases.