Perpetual KYC that refreshes only what changed, with an analyst and a different QC reviewer on every change
Every customer file kept current every day, with only the sections that changed refreshed.
See one case, screen by screen ↓Perpetual KYC refreshes customer due diligence when risk changes, not on a calendar. In this solution, agents watch trigger events from the registry, the core, screening, adverse media, transaction monitoring and the client lifecycle system, decide whether each one is material under the bank's own trigger policy, and refresh only the sections of the customer file it touches. A KYC analyst prepares each change and a different QC reviewer approves it.
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Most banks still refresh customer due diligence on a calendar: every high-risk file every year, medium every three years, low every five, and each one a full review of every section of the file, whether anything changed or not. The customer is asked again for documents already on file. Yet the CDD rule asks banks to update customer information on a risk basis, and FinCEN has said there is no categorical requirement to refresh it on a fixed schedule. Perpetual KYC refreshes the file when normal monitoring shows that something relevant changed.
Meanwhile the changes that matter arrive between the dates: a new 30% owner abroad, a new country, a politically exposed person as a control person. Where banks do watch events, analysts close most of them by hand with no recorded reason, and nobody tests whether those closures were right, so an examiner cannot see it either. And one sanctions list update or one change to the country risk policy touches thousands of customers at once, each of them a ticket.
Estimated split of the people's working time to bring one corporate customer's file up to date after a change of ownership: a full periodic review by hand, against a refresh of the touched sections with the solution. It leaves out the weeks spent waiting on the customer.
A Watcher links each event, a Materiality agent decides it, four agents refresh the touched sections; analyst and QC approve.
Thursday, October 22, 2026, at Corvane National Bank. Tidewater Freight Brokers LLC, a Delaware LLC in Charleston, South Carolina, is a freight broker rated Medium, last fully reviewed on March 11, 2025. At 9:14 AM a filing arrives from the Panama Public Registry. Here is what happens next, screen by screen, in the working solution.
Since midnight 2,318 trigger events have come in: 146 material and sent to analysts, 2,172 recorded with a reason. The newest says “New 30% owner filed with the Panama registry”: Marisol Logistics Holdings, S.A. has bought a 30% membership interest in Tidewater. Lines run into §2 Beneficial owners and control and §5 Geographies; the other seven sections stay gray with their own last-reviewed dates.
Material · confidence 0.96: “Re-screened the new owner (no match), risk rating moves from Medium to High, needs an analyst.”
The agent decides the event against Corvane's trigger policy. Rule T-07: a new direct or indirect owner of 25% or more. Rule T-12: ownership through a tier-3 country in the bank's country risk policy CR-2026.2. Asked “Why is this material?”, it explains that Esteban Ruiz Calderón now owns 30% of Tidewater indirectly through Marisol, and cites both rules and the registry entry.
“Either rule alone would make it material.”
Not every event is material, and none is closed silently. Lena Marsh, a Low-risk consumer customer, moved from Ohio to Florida. Rule T-02 makes a move within the United States not material unless the new address is a commercial mail receiving agency, a PO box or a tier-3 country, so the agent records the call with that rule and reason.
“Recorded at 9:11 AM with its reason · sampled for today's QC.”
The event is routed to Priya with a High-tier SLA, due Friday at 9:18 AM. The KYC refresh opens as a guided step bar, from detection to the systems of record. §2 shows Dana Whitcombe 60% → 42% and Luis Ortega 40% → 28%, with two new rows: Marisol Logistics Holdings, S.A. at 30% direct and Esteban Ruiz Calderón at 30% indirect.
Refresh EV-1022-0914 · 2 of 9 sections touched · Analyst (maker): you are here.
She clicks the citation on the new owner. Panama Public Registry entry 2026-0091-4471 opens with the lines the agents used highlighted: Resolution 2, the acquisition of a thirty percent membership interest in Tidewater, sellers Dana Whitcombe (18%) and Luis Ortega (12%), and Esteban Ruiz Calderón as shareholder of record of 100% of Marisol's shares.
Marisol has no candidate above the 0.85 name threshold. Esteban Ruiz Calderón has two similar names on a sanctions list, both cleared on date of birth and nationality; he is not a PEP, and the 4 adverse media articles are about a namesake. The customer risk rating model CRR v4.2 moves Tidewater from Medium 41 to High 63: geography 4 → 18, ownership structure 6 → 14.
“Proposed. It applies only after the analyst and a QC reviewer approve.”
The agent drafts a secure message to Dana Whitcombe, managing member, from relationship manager Owen Pryce: a signed beneficial ownership certification listing each person who owns 25% or more, and Marisol's current share register, by November 5, 2026. Its tipping-off check removed one phrase. Priya can edit the draft; it is sent only after QC approves.
Removed: “…because our monitoring identified a new owner…”
Priya adds a note to §5, suggested from the wire history: “No Panama transaction activity in the last 12 months: wire history reviewed.” She approves with a reason code, and the refresh moves to QC, 11 minutes after it was routed to her.
“A KYC QC reviewer approves every change to the record and rating. You cannot approve your own work.”
Daniel sees five items, each with its evidence: §2, §5, the rating Medium 41 → High 63, the request to Dana Whitcombe and an EDD review due November 21. He could return any one alone, with a reason. Approving writes the sections to the client lifecycle management system and the High rating to the core banking system, sends the request and opens the EDD review in case management.
“Approved by Daniel Okonkwo at 10:06 AM. Checker differs from maker (Priya Natarajan).”
Tidewater's file now shows §2 and §5 reviewed on October 22, 2026, beside the full review of March 11, 2025 and event refreshes on July 14 and October 8, 2026. Under a 36-month calendar, the next full review was due in March 2028. Now the High rating sets a backstop review for October 22, 2027, in case no trigger arrives first.
Four people at Corvane National Bank who keep its customer files current: what their week looked like, and what it looks like now.
A Watcher links each event, a Materiality agent decides it, four agents refresh the touched sections; analyst and QC approve.
Reads six feeds (the corporate registry data service, the core banking system, sanctions and PEP screening, the adverse media service, the transaction monitoring system and the client lifecycle management system), removes duplicates and links each event to a customer and the sections it may touch.
Decides each event material or not material under the bank's versioned trigger policy, with a plain-language reason, the rule and a confidence.
Refreshes only the sections an event touches and drafts each new value with a citation to the registry entry, the client lifecycle record or the document on file.
Re-screens new or changed parties against sanctions, PEP and adverse media, and cites the identifiers used to clear each similar name.
Re-runs the customer risk rating model CRR v4.2 on the factors that changed and shows each factor's before and after.
Drafts requests to the customer for what is missing and runs the tipping-off check on every message.
Draws the daily 10% sample of “no action” calls, stratified by trigger family, tracks pass rates and opens a rule review when a family falls below 97%.
Maker prepares, a different checker approves. The agents propose; a named person decides.
Pick a suggested question or type your own. Every answer cites the trigger rule, the record or the policy it relies on.
Why is this material?
Two rules fire. T-07: Esteban Ruiz Calderón now owns 30% of Tidewater indirectly, through Marisol Logistics Holdings, S.A., above the 25% beneficial-ownership line. T-12: that ownership runs through Panama, tier 3 in Corvane's country risk policy CR-2026.2. Either rule alone would make it material.
Why is Tidewater's rating now High?
Two factors moved in CRR v4.2. Geography went from 4 to 18 because 30% of Tidewater is now owned through Panama, tier 3 in policy CR-2026.2. Ownership structure went from 6 to 14 for the new foreign corporate layer. 41 becomes 63, and High starts at 60. It is proposed: it applies only after the analyst and a QC reviewer approve.
Show me “no action” calls QC disagreed with this month
Five, all in Screening and media, rule T-19: civil lawsuits with money claims over $1 million that the rule records without review. That is why the family's pass rate is 96.1%, under the 97% floor. Draft v2026.4 would make those material.
Which customers did last night's sanctions list update touch?
3,964 customers have a party with a similar name. 3,941 were cleared on two or more identifiers and recorded, each with the identifiers cited; 23 potential matches went to the Sanctions Screening team, and 394 cleared calls are in QC's sample.
13 screens from the working solution, on its sample data. Pick one to see it large.
SLAs, QC sampling, confidence thresholds, backstop reviews and retention are settings. Every change is saved as a change request that a second administrator approves, and threshold changes are approved by Model Risk too.
| Setting | Default | Choose from |
|---|---|---|
| SLA, High risk tier | 1 business day | 1 business day · 2 business days |
| SLA, Medium risk tier | 3 business days | 3 business days · 5 business days |
| QC sample rate | 10% of not-material calls, every day | 5% · 10% · 15% · 20% |
| Pass-rate floor | 97% | 95% · 97% · 98% |
| Materiality confidence, below which an analyst decides | 0.80 | 0.75 · 0.80 · 0.85 |
| Customer link confidence, below which an analyst confirms | 0.90 | 0.85 · 0.90 · 0.95 |
| Backstop review, High, if no trigger arrives | 12 months | 12 months · 24 months |
| Retention | 5 years after the account closes | 5 years after closing · 7 years after closing |
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 · “typical” = published figures (a 2025 industry survey of 800 financial institutions on KYC spend: about $2,200 per corporate review, and 61–150 days per corporate review at more than half of institutions). Rules named for context: 31 CFR 1020.210 (updating customer information on a risk basis), 31 CFR 1010.230 (beneficial owners), 31 CFR 1020.320(e) (SAR confidentiality), 31 CFR 1010.430 (five-year retention) and FinCEN's CDD FAQs. Banks, companies, people, registry entries and identifiers named on this page are fictional: characters and sample data in the working solution.
Perpetual KYC refreshes customer due diligence when risk changes, not on a calendar. In this solution, agents watch trigger events from the registry, the core, screening, adverse media, transaction monitoring and the client lifecycle system, decide whether each one is material under the bank's own trigger policy, and refresh only the sections of the customer file it touches. A KYC analyst prepares each change and a different QC reviewer approves it.
A periodic review re-collects the whole file on a fixed date, every one, three or five years by risk tier, whether anything changed or not. Perpetual KYC refreshes the file when a trigger event shows that something relevant changed, and only the sections that event touches; each section keeps its own last-reviewed date. A backstop review still runs if no trigger arrives, 12 months for a High-risk customer by default. KYC remediation is different again: a time-boxed program on the existing customer base.
The Materiality agent reads each event against the bank's versioned trigger policy (rules such as a new owner of 25% or more, or ownership through a tier-3 country) and writes a verdict with the rule, a plain-language reason and a confidence. Below 0.80 confidence the event goes to an analyst, and the agent never closes a material event.
Every not-material call is recorded with its rule and reason. The QC Sampler sends 10% of them to QC reviewers each day, stratified by trigger family, and reports pass rates over time. When a family falls below the 97% floor, a rule review opens for the Head of KYC Operations.
The agents group it into one cluster. In the working solution, a sanctions list update touched 3,964 customers: 3,941 were cleared on two or more identifiers and recorded, and 23 potential matches went to the Sanctions Screening team. Rating changes from a policy change are prepared as one batch with a QC sample for a checker to approve.
Yes. The agents never write to a customer record, apply a rating, send a message, clear a potential true match or change a rule. An analyst prepares every change with a reason code, a different QC reviewer approves it, and only then is it written to the client lifecycle management system and the core banking system.
No. Restricted referrals are visible only to the BSA Officer and never appear on a customer-facing view, and the Outreach agent checks every message to a customer for tipping off, removing any phrase that refers to monitoring, alerts, investigations or reports.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your CDD standard, trigger policy, customer risk rating model and a sample of past trigger events and customer files. It goes live once every quality gate has passed. We will walk you through it on your own events first.
Back-book files made current from records you already hold, asking members only for gaps.
1-min demoDeposit Account OpeningClean 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 demoWe'll run Perpetual KYC on a sample of your own past trigger events and customer files.