What belongs in a CDD exception and remediation workflow?

Separate the workflow from the decision

An exception workflow can organise facts, owners, deadlines and escalation paths. It should not pre-empt the qualified human judgement required for a material AML decision. Keep decision authority explicit in the approved framework.

Core workflow fields

• Unique internal reference, control area and date identified.
• High-level issue category without exposing unnecessary sensitive information.
• Assigned owner, reviewer and escalation point.
• Priority, target date and dependencies.
• Required evidence and secure storage location.
• Decision record, approval within authority and closure checks.
• Trend category for management reporting.

Public channels are not the workflow

Do not send customer identity documents, CDD files, transaction records or suspicious-matter details through a public website or ordinary email. Agree secure, access-controlled arrangements before exchanging case material.