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A KYC (Know Your Customer) refresh is the process of periodically updating and verifying the information and risk profiles of existing customers to ensure compliance with regulatory requirements and to manage potential risks associated with money laundering, terrorist financing, and other financial crimes.

Key Points:

  1. Purpose: The primary objective of a KYC refresh is to maintain accurate and current customer information, ensuring that financial institutions can effectively assess and manage customer risks over time.
  2. Components of a KYC Refresh:
    • Customer Information Update: Collecting updated personal or business details, including name, address, contact information, and identification documents.
    • Verification: Confirming the accuracy of the updated information through reliable sources and documentation.
    • Risk Assessment: Re-evaluating the customer’s risk profile based on updated information, transaction history, and any new risk factors.
    • Transaction Analysis: Reviewing recent transaction patterns to identify any unusual or suspicious activities.
    • Beneficial Ownership: Updating information on the ultimate beneficial owners (UBOs) for corporate customers to ensure transparency.
  3. Triggers for KYC Refresh:
    • Periodic Intervals: Conducting refreshes at regular intervals, which may vary based on the customer’s risk level (e.g., annually for high-risk customers, every few years for lower-risk customers).
    • Significant Changes: Initiating a refresh when there are significant changes in customer information, such as a change of address, job, or business structure.
    • Suspicious Activities: Triggering a refresh when suspicious transactions or activities are detected through ongoing monitoring.
    • Regulatory Changes: Performing refreshes in response to new regulatory requirements or changes in AML/CTF laws.
  4. Process of Conducting a KYC Refresh:
    • Data Collection: Gathering updated information from the customer through direct communication, online forms, or automated systems.
    • Document Verification: Verifying updated information using government-issued IDs, third-party databases, or other reliable sources.
    • Risk Reassessment: Reassessing the customer’s risk profile using updated information and recent transaction data.
    • Record Keeping: Documenting the refresh process, including any changes made to the customer’s profile and the rationale behind those changes.
    • Actionable Outcomes: Taking appropriate actions based on the refresh findings, such as updating risk scores, applying enhanced due diligence, or filing suspicious activity reports (SARs).
  5. Regulatory Framework:
    • Financial Action Task Force (FATF): Provides international guidelines and recommendations for ongoing customer due diligence and KYC refresh practices.
    • Local Regulations: Jurisdictions have specific AML/CTF regulations requiring periodic updates and verifications of customer information.
  6. Challenges in KYC Refresh:
    • Data Accuracy and Completeness: Ensuring the updated information provided by customers is accurate and comprehensive.
    • Customer Engagement: Encouraging customers to respond promptly and provide necessary updates.
    • Resource Allocation: Managing the resources required to conduct thorough KYC refreshes without disrupting operational efficiency.
    • Integration and Technology: Effectively integrating data from various sources to maintain a holistic view of the customer’s profile and risk.
  7. Technological Solutions:
    • Automated KYC Platforms: Using automated systems to streamline data collection, verification, and risk assessment processes.
    • Machine Learning and AI: Implementing advanced technologies to identify changes in customer behavior and risk patterns.
    • Data Analytics Tools: Leveraging analytics to review transaction history and detect unusual activities.
  8. Examples of KYC Refresh Practices:
    • A bank conducts a biennial refresh for all high-risk customers, updating their personal information and verifying new documents.
    • A financial institution initiates a KYC refresh for a corporate client following significant changes in the company’s ownership structure.
    • An online payment platform uses automated alerts to request updated identification documents from users whose information has not been refreshed within the last two years.
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