Due Diligence and Ongoing Monitoring

Hello! Does ongoing monitoring need to be completed within the same calendar year of the next scheduled review date or by the actual date of the next scheduled review? For example, I have a high risk vendor who needs to be reviewed annually. We started their annual review April 2023, but it took quite awhile to get the required / proper documentation from them, so the 2023 reviews were just finalized in Feb 2024. Should their next review date be April 2024 or should I just try to have those completed by year end since high risk vendors are on an annual cadence? 

Thanks in advance for your help!

We have a schedule set for 10 months out of the year for every department. For a department that only has a couple of vendors to be reviewed, and we find that maybe one vendor is late with sending us their due diligence we move the whole department to a different month. For other departments, like IT that have so many vendors to review, I complete the vendors we have docs for and report them to the board along with a list of which vendors could not be completed and why. Once they are completed, I send the same list to the board again but this time with a part 2 showing the vendors that previously weren't completed. 

Knowing how long it takes to gather financials for some vendors we have made sure they are scheduled towards the end of the year in Oct or Nov.

We just recently changed our Policy to state "once per calendar year" vs. annually to deal with the issue of how long it takes to get docs from some vendors.  We also have a vendor do the ongoing due diligence reviews for most of our higher risk vendors and they start those reviews in April of each year. So, this policy change was also made to accommodate this schedule. If we find that we won't be able to complete a DD review on time, we would notify the Board.

We have a critical vendor review "season" per say. We start around April and typically wrap up reviews and board presentations by the end of the summer. Vendors that take longer to respond get reported later in the season. I'll review the dates of the documents that I have when we start to see if they would still be applicable to the time period of the current review season that we're in or if the vendor likely has a newer document available.