Periodic Reviews

The review scheduler decides which customers to pull for a refresh and when. Each customer is scheduled from its risk rating: Low every 36 months, Medium every 24, High every 12. Trigger events, such as a change in ownership or a monitoring alert, bring a review forward. Grounded in the Onboarding and Transaction Monitoring Procedure.

Reviews in scope

CDD samples 100001 to 100005

Overdue

Pull first

Due within 30 days

Plan into the queue

Scheduled

No action needed yet

Review queue

Ordered by urgency

Reference	Customer	Risk	Cadence	Owner	Due date	Timing	Status
100002	Netanel Adrai Pagima Individual	Low	36 months	Asher Freed	05 Jul 2026	Overdue by 12 days	Overdue
100004	La Lucia LTD Corporate	Low	36 months	Asher Freed	12 Jul 2026	Overdue by 5 days	Overdue
100005	Staff Connect Resourcing Limited Corporate	Medium	24 months	Asher Freed	01 Aug 2026	Due in 15 days	Due soon
100001	David Lipson Individual	Low	36 months	Asher Freed	06 Aug 2026	Due in 20 days	Due soon
100003	Reportly Limited Corporate	Medium	24 months	Asher Freed	26 Aug 2026	Due in 40 days	Scheduled
100006	QA Test Holdings Ltd Corporate	High	12 months	Trevor Clein	17 Jul 2027	Due in 365 days	Scheduled
100008	Sentinel QA Global Trading Ltd Corporate	High	12 months	Trevor Clein	17 Jul 2027	Due in 365 days	Scheduled
100013	Jonathan Blake Individual	Medium	24 months	Asher Freed	17 Jul 2028	Due in 731 days	Scheduled
100014	Jonathan Blake Individual	Medium	24 months	Asher Freed	17 Jul 2028	Due in 731 days	Scheduled

Review cadence by risk rating

Risk rating	Refresh cycle	Basis
Low	36 months	Standard due diligence. Refresh every three years.
Medium	24 months	Standard due diligence with closer monitoring.
High	12 months	Enhanced due diligence. Annual refresh, MLRO oversight.

Prohibited business is refused at onboarding and never scheduled. A review can be brought forward at any time by a trigger event: a change in ownership or control, a monitoring alert, adverse screening, or a change in the customer profile.