KYC remediation that searches your own records before anyone writes to a customer, and puts every closure in front of a maker and a checker
Back-book files made current from records you already hold, asking members only for gaps.
See one case, screen by screen ↓KYC remediation brings existing customer files up to current CIP, CDD and EDD standards after a merger, a consent order or a new standard. KYC Remediation sorts the back book into cohorts by gap, closes each gap it can from records the institution already holds with the record cited, asks customers only for what is missing in one message, and puts every file or batch in front of a maker and a different checker.
AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →
Updated
KYC remediation starts when thousands of existing files fall short of the standard at once: after a merger, a consent order or a new CIP, CDD or EDD standard. Today contractor teams open every file one by one, as if nothing were known about the customer. They ask for a certification of beneficial owners that already sits in a business loan file, or a renewed license imaged at a branch, and they write once per gap, so the same customer is contacted several times.
The letters go out in waves that flood the contact center, and nobody can say how many calls next week's batch will cause. Progress lives in spreadsheets, so when the board, the Supervisory Committee or an examiner asks when the back book will be current, nobody can answer with evidence. Customers who never reply are restricted inconsistently, sometimes with letters that hint at monitoring, and sometimes vulnerable people first.
Estimated split of an analyst's and a reviewer's working time on one business member file, by hand and with the agents. It leaves out the time the member takes to reply. Our arithmetic, kept modest.
A Gap Finder sorts the back book, a Records Searcher closes from your records; maker and checker approve.
Norrell Federal Credit Union, a $6.8 billion credit union, took on 38,400 member files in its merger with Basin Valley Credit Union and committed to bring every one to its own CIP and CDD standard by June 30, 2027. Here is one Thursday morning, screen by screen, in the working solution.
Four cohorts, one bar each: expired or missing ID (14,200), beneficial owners not verified (6,120), nature and purpose missing (11,480) and risk rating out of date (6,600). Each bar shows what is done, closed from our records, with a reviewer, requested from the member and not started. The burn-up shows 7,840 files done, 32 days ahead of plan, and under it Keisha's one next step: "Approve 214 files closed from our own records".
Overnight: 214 files closed from our records, 96 member replies read, 63 response windows ended, 1,206 members screened, no match.
Keisha opens the 6,120 business files without verified beneficial owners; 5,614 are not started. A file closes from our records only with a signed certification of beneficial owners in a business loan file, the owners' IDs imaged with it, and a state annual report from the last 12 months listing the same owners. The loan origination system was connected yesterday at 4:10 PM, so she starts the search.
"5,614 business requests are held until this search finishes."
The Records Searcher finds a signed certification for 5,222 of the 5,614 files and current IDs for 11,215 of 11,874 owners and control persons; 4,103 certifications agree with the latest state report and 1,119 show a changed owner or officer. The Screening agent screens all 11,874 owners through the OFAC screening service: no match, with 6 similar names cleared on date of birth and address. 3,982 files are closed from our records; 1,240 need one item from the member and 392 a full request.
Pellwood Haulers Inc. could not be searched: the agents retry at 9:40 AM, and no member is contacted.
Keisha clicks a source on Halvorsen Orchard Supply LLC. The certification of beneficial owners opens from the loan origination system with the lines the agent used highlighted: Erik Halvorsen 55% and control person as managing member, Ingrid Halvorsen 45%, signed April 18, 2023 at an equipment loan closing. The same two members are on the March 9, 2026 Idaho annual report.
Batch B-1022-BO, 3,982 files, moves to the checker. A beneficial owner batch always goes to the BSA Officer, who draws a sample stratified by loan type: equipment loans 12, commercial real estate 11, operating lines 10, vehicle loans 7.
"Approved as maker. Sent to Ruth Abernathy to check."
For each sampled file the agents re-read the certification, the owners and the state report, and Ruth can open any source. One error would send its stratum back for full review. All 40 match.
"40 of 40 match their sources · 0 errors. With no errors in 40, there is 95% confidence that fewer than 7.2% of the batch has an error."
Ruth approves with the reason "Sample passed with no errors". The owners of 3,982 business members are written to the core banking system with their evidence, and 3,982 member requests will never be sent. The cohort now shows 4,392 of 6,120 files done.
"3,982 files approved: 61 days ahead of plan."
The program now has 11,822 of 38,400 files done, 61 days ahead of the plan line to June 30, 2027. Ruth's next step is already on the page: 63 members are past their response window.
Every gap a member has goes in one plain message: Rafael Ibarra gets two items from two cohorts, a current ID and three short questions, in Spanish, his preferred language on the core record. Each message passes a tipping-off check and a plain-language check. Darnell Whitaker, the contact center supervisor, caps the week at 1,200 consumer and 450 business messages, so expected calls stay under the 480 his team is staffed for.
"Approving batch B-1022-BO removed 3,982 business requests: about nine weeks of Business Member Services capacity."
Of the 63 members past their window, the agent recommends a limit for 51, a call first for 7, a hold for 3 who have since replied and closing accounts for 2. Gordon Teague, 81, with Social Security deposits, gets a call first. Travis Kendrick, asked five times since June, gets a limit from November 9, 2026 only after an analyst prepares it, a quality reviewer checks the notice and the BSA Officer approves; his deposits, direct deposits and loan payments continue.
Four people at Norrell Federal Credit Union who bring 38,400 acquired files to standard: what their week looked like, and what it looks like now.
A Gap Finder sorts the back book, a Records Searcher closes from your records; maker and checker approve.
Tests every acquired file against the program's standard and sorts it into cohorts by gap and risk, keeping every gap a file has.
Searches the loan origination system, document imaging, account history and state business filings, and proposes closing a gap with every line it used cited.
Screens every member, beneficial owner and control person through the OFAC screening service.
Re-rates a member under the credit union's risk model once the file's other gaps close.
Builds each file package and batch with the record before and after, the sources and the agents' steps, for a maker and a checker.
Drafts one plain message per member with every gap across cohorts, in the member's language, and paces messages to what the contact center can answer.
Tracks each member's response window and recommends a call, a limit on services or closing accounts, with a drafted notice.
Keeps the burn-up against the plan line, the days ahead or behind, and drafts the monthly report to the board and the Supervisory Committee from the program record.
Maker approves, a different checker samples. The agents propose; a named person decides.
On any member file, ask why it was closed, asked or held. Every answer points to the record behind it.
Why is a 2023 certification good enough?
Norrell's program scope v3 accepts a certification signed since May 11, 2018 when a state annual report from the last 12 months lists the same owners. The certification was signed April 18, 2023, and the March 9, 2026 Idaho report lists Erik and Ingrid Halvorsen and no one else.
Why not close it from the 2019 certification?
Because the state report now lists a second member, Dr. Naomi Castillo, who is not on the certification. The agents never close a file when the records disagree; they ask for only the item that would settle it.
Will the member be contacted while this is stuck?
No. A request is drafted only after the search finishes, so the member is never asked for something Norrell may already hold.
Why limit services and not close?
Norrell's program limits services first and keeps deposits flowing: payroll still lands and loan payments are still taken. Closing accounts is considered only after 60 more days with no reply, and expelling a member is a separate board process the agents never recommend.
13 screens from the working solution, on its sample data. Pick one to see it large.
Thresholds, samples, message caps and notices are settings. A change goes to a second administrator as a change request, and the rules that protect members are locked on.
| Setting | Default | Choose from |
|---|---|---|
| Batch size that needs the BSA Officer | 500 files, and every beneficial owner batch | Any number of files; beneficial owner batches always go to the BSA Officer |
| Sample for a batch under the threshold | 20 files, stratified | Any size; any error returns the stratum |
| Sample for a large batch | 40 files, stratified | Any size; zero errors in 40 gives 95% confidence that fewer than 7.2% are wrong |
| Agents close a gap at | 0.95 match confidence | Any confidence; below it, a person decides |
| Member messages a week | 1,200 consumer · 450 business | Set by the Member Contact Center Supervisor |
| Reminders and final notice | Day 10 by text, day 20 by a call; final notice on day 30 with a 14-day window | On · Off |
| Spanish when the member prefers it | On, from the language on the core record | On · Off |
| Reviewer SLA | High risk 2 business days · Medium and Low 5 | Business days, per risk level; overdue High-risk files go to the BSA Officer daily at 7:30 AM |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate (the time split on one business file) · “typical” = published figures (vendor-sourced industry survey figures on corporate KYC reviews: 61–150 days at more than half of institutions, about $2,000–$2,500 per review; directional). Rules named for context: FinCEN's beneficial ownership requirements, 31 CFR 1010.230; the CIP rule, 31 CFR 1020.220; the NCUA BSA program rule, 12 CFR 748.2; BSA record retention, 31 CFR 1010.430; SAR confidentiality, 31 CFR 1020.320(e). The credit unions, businesses, people and files named on this page are fictional: characters and sample data in the working solution.
KYC remediation brings existing customer files up to current CIP, CDD and EDD standards after a merger, a consent order or a new standard. KYC Remediation sorts the back book into cohorts by gap, closes each gap it can from records the institution already holds with the record cited, asks customers only for what is missing in one message, and puts every file or batch in front of a maker and a different checker.
The Gap Finder tests every file against the standard and sorts it into cohorts. The Records Searcher searches loan files, ID images, account history and state filings, and closes a gap only when the sources agree. An analyst approves the batch as maker, a quality reviewer or the BSA Officer samples it and approves, and the changes are written to the core with their evidence. Only then does the Member Request agent draft one paced message per customer for what is still missing.
Back book remediation is a time-boxed program on the existing customer base after a policy change, a merger or a regulatory finding. A KYC refresh, or periodic KYC review, is the steady-state cycle that keeps files current afterwards. KYC Remediation runs the program, with a target date, a plan line and a burn-up the board can read.
FinCEN's beneficial ownership rule (31 CFR 1010.230) asks for each person owning 25% or more and one control person. In the sample program a file closes only when a signed certification in a business loan file, the owners' current IDs imaged with it and a state annual report from the last 12 months list the same owners. Every owner and control person is screened, and when the records disagree the customer is asked for only the item that settles it.
No. Every gap a customer has goes in one plain message, and the Member Request agent spreads messages over the weeks so expected calls stay under what the contact center is staffed for. The contact center supervisor sets the weekly caps, and a quality reviewer approves each week's release.
The Non-response agent recommends a call, a limit on services or closing accounts. Vulnerability signals always mean a call first. A limit needs an analyst to prepare it, a reviewer to check the notice and the BSA Officer to approve it; the notice says what continues and how to fix it, and deposits keep flowing.
Yes. The agents search, propose and draft; they never write to a customer record, send a message, limit services, close accounts, clear a potential sanctions match or apply a risk rating. Every decision has a maker and a different checker, overrides carry a reason code, and agent versions are approved by the BSA Officer.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your CIP and CDD standard, your remediation scope and a sample of back-book files, and it goes live once every quality gate has passed. We will walk you through it on your own files first.
Clean applicants open in minutes; every referral says why and is decided the same day.
1-min demoBusiness Account Opening (KYB)Standard business accounts opened the same day, with every owner verified and on file.
1-min demoCorporate KYCCorporate files approved in days, not months, with every chapter cited and checked.
1-min demoWe'll run KYC Remediation on a sample of your own files, your standard and the records you already hold.