KYC and Customer Due Diligence
A KYC framework should help teams understand who a customer is, why the relationship makes sense, and when new information changes the risk picture. A defined review can examine how customer due diligence works from onboarding through periodic and event-driven review.
Beneficial Ownership Review
Trace complex ownership and control through a documented evidence chain, assess registry limitations and support proportionate KYC decisions across jurisdictions.
Read moreCDD across the customer relationship
The relevant due diligence steps depend on the relationship, risk and applicable jurisdiction. FATF Recommendation 10 sets out international standards for identifying and verifying customers, understanding the purpose and intended nature of a relationship, and conducting ongoing due diligence. Countries implement those standards through their own legal and supervisory frameworks.
Advice can examine how policy becomes a customer journey: what is collected at onboarding, how customer risk ratings are assigned, and how that rating affects evidence requirements, approvals and review frequency. It can also consider what should prompt an out-of-cycle review, such as a material change in activity or information that no longer fits the known customer profile.
Risk ratings and evidence that supports decisions
A customer risk rating is useful when its factors are understandable and lead to proportionate action. A review may explore how customer type, products, delivery channels, geography and expected activity shape the assessment; how higher-risk relationships receive enhanced checks; and how staff can explain and escalate an unusual result. The right factors and measures depend on the business and local requirements.
Evidence quality matters as much as the checklist. Check whether information is current, complete, traceable to a reliable source and consistent across records, and how staff handle gaps or conflicts. Public registries can help, but their coverage, access and reliability vary. A 2019 NICE Actimize article to which Trevor Barritt contributed research and content compared registry approaches across several regions.
A bounded framework or process review
An initial conversation can clarify the jurisdiction, customer types, review concern and decision the team needs to make. If the scope fits, useful inputs might include due diligence policies, risk-rating methodology, process maps, exception themes and appropriately protected sample records. The discussion can identify where criteria, evidence standards, hand-offs or review triggers need clearer definition, then agree any priorities or written output in advance.
Complex beneficial ownership and control structures, registry limitations and cross-border differences can require deeper analysis than a general customer journey review. Advice focuses on the firm's framework and process. Identity verification, onboarding operations and verification technology are separate activities.
Common questions
How are CDD and enhanced due diligence different?
CDD is the due diligence applied to understand and verify a customer and relationship. Enhanced due diligence adds measures appropriate to higher-risk circumstances under the applicable rules and the firm's approach based on risk. The exact requirements vary by jurisdiction.
Does a KYC framework review verify customer identities?
No. The advice reviews a firm's KYC and due diligence framework or process. Identity verification and verification technology are separate activities.