playbooks/bsa-aml/cdd-drift-comparison-template

CDD Drift Comparison Template

A side-by-side comparison framework for spotting CDD profile drift — expected behavior at onboarding vs. actual transaction patterns at review.

cdd-drift-comparison-template.mdTemplate · 7 min

Contents

  1. 01What this template helps you do
  2. 02When to use it

For: BSA / AML analysts during CDD refresh cycles

PlaybooksBSA / AMLTemplate

01

What this template helps you do

This template is structured. The working copy is being finalized by our subject-matter editors — directionally accurate today, refined shortly.

  • Capture the expected-behavior baseline established at onboarding in structured fields, not narrative.
  • Surface the actual-behavior pattern from the review period in the same field shape, side-by-side.
  • Make the drift visible — the template highlights field-level deltas so the reviewer can confirm whether escalation is warranted.

02

When to use it

  • CDD refresh cycles for high-risk customers.
  • Investigating an alert where the customer profile may have shifted since onboarding.

BSA / AML Playbook

Practice this in the course.

The AiBI-Foundation course walks through the same prompts, with reviewed work you can take to your team.

CDD Drift Comparison Template — BSA / AML Playbook — The AI Banking Institute