The FinCEN CDD Rule brought focus to the issues surrounding Customer Due Diligence, which includes the broader concept of CIP. CDD has significant implications for understanding of beneficial ownership and PEPs. However, financial institutions who offer correspondent banking, especially foreign correspondent banking, challenges them to “dig deep” into their correspondent accounts and assess their risk to the institution. Although an implementation challenge, CDD enables FIs to have an even more comprehensive understanding of their customers. With this in mind, we will explore the implementation challenges with a focus on higher risk scenarios and the feedback FIs have received thus far with the changes they’ve seen to their programs.