Data collected under CDD must be kept up-to-date, accurate and relevant. The Licensed Person must undertake annual or as-needed reviews of existing records, particularly for high risk categories of clients or business relationships when trigger events occur, such as: 1. An existing client applying to open a new account or establishing a new relationship, or significantly altering the nature of the existing relationship; 2. When there is a transaction that is unusual or not in line with the client’s normal trading patterns based on the Licensed Person’s knowledge of the client; 3. When the Licensed Person is not satisfied that it has sufficient information about the client or has doubts about the veracity or adequacy of previously obtained data.