How to Create a Know Your Customer (KYC) Checklist | FDM Group (2024)

Know Your Customer (KYC) and Anti-Money Laundering (AML) processes are pivotal in the financial landscape, serving as a critical safeguard against illicit activities. KYC involves verifying the identity of clients, while AML focuses on preventing money laundering. A robust KYC framework is indispensable in combating financial crimes, maintaining regulatory compliance, and mitigating reputational risk for businesses. By establishing a thorough KYC process. Institutions can enhance security measures, ensure transparency, and foster trust within the financial ecosystem.

We’ve put together a KYC checklist to help you develop a fool-proof process and ensure a robust frontline defence against criminal activities.

• Executive summary
• What is KYC compliance?
• The 3-step Know Your Customer (KYC) checklist
• You’ve defined your KYC checklist: what’s next?
• How does a KYC checklist process vary by industry?
• Compliance vs customer experience
• How can automation simplify your KYC checklist?
• Does your organisation need a KYC Analyst?

Executive summary

Know Your Customer (KYC) compliance is essential for businesses and financial institutions to verify client identities, prevent illicit activities, and maintain regulatory compliance. Businesses should adopt a simple KYC checklist to ensure this, including three easy steps: Customer Identification (CIP), Customer Due Diligence (CDD), and ongoing monitoring.

Implementing this checklist requires seamless integration, staff training, the right technology, documentation processes, regular review, and communication with stakeholders. Also, industry-specific variations exist, and achieving a balance between compliance and customer experience is crucial. With years of experience offering AML-KYC PODs for businesses to navigate the evolving KYC landscape, our experts provide their KYC checklist best practices.

What is KYC compliance?

Know Your Customer (KYC) compliance is a set of procedures and protocols implemented by businesses and financial institutions to verify and authenticate the identity of their clients. The objective is to prevent illicit activities such as money laundering, fraud, and financing illegal activity.

KYC involves rigorous customer identification, thorough due diligence, and continuous monitoring of transactions. By confirming the legitimacy of clients, KYC compliance not only ensures regulatory adherence but also mitigates risks associated with financial crimes. It is a fundamental framework for maintaining transparency, integrity, and security in various industries, ranging from banking and finance to e-commerce and beyond.

In the United Kingdom, several regulatory bodies and authorities are specifically involved in monitoring KYC and AML efforts, including the following:

• Financial Conduct Authority (FCA)
• Prudential Regulation Authority (PRA)
• National Crime Agency (NCA)
• HM Revenue & Customs (HMRC)
• Financial Intelligence Unit (UKFIU)

These agencies work collaboratively to ensure compliance with AML regulations, investigate suspicious activities, and maintain the integrity of the UK’s financial system. It is imperative that you familiarise your business with these bodies in order to ensure compliance, manage risks, fulfil your legal obligations, and manage your reputation.

The 3-step Know Your Customer (KYC) checklist

We’ve created a practical checklist to simplify the KYC processes across your organisation:

1. Customer identification programme (CIP)

The Customer Identification Programme (CIP) is a crucial aspect of KYC processes, typically occurring during the onboarding phase. Its primary objective is to collect essential customer information to verify identities and ensure compliance with regulatory standards. Basic details, including name, date of birth, address, and identification numbers, are typically gathered to establish a comprehensive customer profile.

The CIP involves a structured process that may include document verification, biographical information cross-checks, and risk assessments. This stage lays the foundation for further due diligence and monitoring.

To fulfil CIP requirements, businesses commonly request the following KYC documents:

• Photo identity cards, such as driver’s licences or national ID cards
• Proof of address, such as on utility bills or bank statements
• Passports, which are considered primary identification documents

In addition to individual customer identification, KYC practices extend to businesses. KYB involves understanding the business entity’s structure, purpose, and ownership. Key elements include:

• Business identification numbers, such as the company registration number
• Ultimate Beneficial Owners (UBOs), which identifies individuals with significant control over the business

2. Customer Due Diligence (CDD)

Customer Due Diligence (CDD) is an essential process that goes beyond the initial Customer Identification Programme (CIP). CDD involves a more in-depth examination of the nature of customer activities, assessing the level of risk they pose, and ensuring ongoing compliance. It is a critical step in understanding and managing the potential risks associated with customers.

The key tools and processes involved in CDD include:

• Transaction monitoring systems: Automated tools that analyse and flag unusual or suspicious transactions for further investigation.
• Watchlist screening: Checking customer names against global watchlists to identify politically exposed persons (PEPs) or individuals associated with illegal activities.
• Biometric verification: Utilising biometric data, such as fingerprints or facial recognition, for enhanced identity verification.
• Data analytics: Leveraging data analytics to detect patterns or anomalies in customer behaviour that may indicate risk.

There are various types of due diligence, including the following:

1. Simplified Due Diligence (SDD): SDD is applied when the customer poses lower risks due to the nature of the product, transaction, business relationship, or their status as a low-risk entity. This is typically used for low-risk customers, regular transactions, or well-established entities with a proven track record.
2. Standard Customer Due Diligence (CDD): CDD is the baseline level of due diligence and is conducted for customers with a moderate level of risk. It involves a comprehensive review of the customer’s background, nature of transactions, and source of funds. IIt is applied to standard business relationships and transactions where the risk is neither very high nor very low.
3. Enhanced Due Diligence (EDD): EDD is a more thorough investigation conducted for higher-risk customers or transactions. It involves gathering additional information and scrutiny to mitigate potential risks effectively. Often. It is applied to customers with complex ownership structures, high transaction volumes, involvement in high-risk industries, or those identified as politically exposed persons (PEPs).

3. Ongoing monitoring

Ongoing monitoring is a crucial component of effective KYC practices, ensuring that businesses stay vigilant to changes in customer behaviour and emerging risks. It goes beyond the initial onboarding phase, recognising that the risk profile of a customer can evolve over time. Regular surveillance helps in identifying and addressing potential issues promptly, maintaining regulatory compliance, and safeguarding against financial crimes.

Utilising standardised systems or integrating new technologies is imperative for efficient ongoing monitoring. This approach ensures consistency, accuracy, and scalability, particularly in environments where large volumes of data need continuous scrutiny. Automation, data analytics, and artificial intelligence play key roles in enhancing the effectiveness of ongoing monitoring, enabling swift identification of anomalies and deviations from established patterns. High-risk clients necessitate heightened levels of ongoing monitoring due to their increased susceptibility to involvement in illicit activities.

Key ongoing monitoring practices to implement include:

• Payment screening: Regular screening of customer transactions against watchlists and databases to identify any links to sanctioned individuals, entities, or illicit activities. This helps to prevent illicit funds from entering the financial system and ensures compliance with international sanctions.
• Customer monitoring: Continuous assessment of customer profiles, evaluating changes in risk factors such as business activities, ownership structures, or legal statuses. These processes enable businesses to adapt to evolving customer risks and maintain an accurate understanding of their clients.
• Transaction monitoring: Real-time analysis of transaction patterns to identify unusual or suspicious activities, flagging potential instances of money laundering, fraud, or other illicit financial practices. This provides a proactive approach to identifying and preventing financial crimes, enhancing overall risk management.

You’ve defined your KYC checklist: what’s next?

Once you have defined your KYC (Know Your Customer) checklist, the implementation process involves several key steps to ensure its effectiveness:

1. Integration into your onboarding process

Integrate your KYC checklist seamlessly into the customer onboarding journey. This ensures that customer identification and due diligence become integral components of the initial engagement, promoting efficiency and compliance from the start.

2. Training and awareness

Conduct comprehensive training sessions for relevant staff, emphasising the importance of KYC compliance. Ensure that team members are aware of the checklist’s significance, regulatory implications, and the role each plays in maintaining effective customer due diligence.

3. Technology implementation

Leverage technology to automate and streamline your KYC processes. Implement software solutions that enhance efficiency, accuracy, and consistency. Technological integration ensures a scalable and dynamic approach to customer identification and risk assessment.

4. Documentation and record keeping

Establish a robust system for documenting and storing KYC information. This includes clear records of customer identification, due diligence outcomes, and any pertinent communication. Organised documentation is crucial for regulatory compliance and internal auditing.

5. Regular review and updates

Conduct regular reviews of your KYC checklist to align with evolving regulatory requirements. Promptly update the checklist to incorporate any changes in guidelines, ensuring that your processes stay current and compliant with industry standards.

6. Communication with stakeholders and across departments

Communicate the updated KYC checklist and procedural changes to relevant stakeholders, fostering awareness and cooperation. Promote cross-departmental collaboration, ensuring that compliance, legal, IT, and customer service teams work cohesively to maintain the integrity of KYC processes.

How does a KYC checklist process vary by industry?

KYC checklist processes may vary across industries, reflecting the diverse regulatory landscapes and risk considerations inherent to each one. In banking and finance, stringent customer identification and transaction monitoring are crucial, aligning with anti-money laundering efforts. Whereas, real estate scrutinises property ownership and source of funds to prevent money laundering. E-commerce prioritises user verification and transaction monitoring for secure online transactions. Meanwhile, in the gaming world, age verification and anti-fraud measures are key.

Compliance vs customer experience

Achieving a delicate equilibrium between compliance and customer experience is a pivotal challenge in the implementation of KYC processes. While stringent compliance measures are crucial for risk mitigation and regulatory adherence, they often intersect with the customer journey, potentially impacting satisfaction.

For example, onboarding delays may test the patience of customers looking for swift transactions and services or the collection of extensive information may raise privacy concerns. To combat this, you must implement streamlined processes for efficiency, provide transparency and good communication with customers, and even leverage innovative technologies, such as biometrics, to enhance the speed of KYC processes.

How can automation simplify your KYC checklist?

Automation plays a pivotal role in streamlining KYC checklists, working hand in hand with KYC Analysts to make KYC procedures more efficient and effective. By automating routine tasks, it enhances efficiency, accelerating the verification process. Automation ensures accuracy by minimising manual errors and repetitive tasks. The adaptability of automated systems allows for swift adjustments to evolving regulatory requirements, keeping the KYC process current. Additionally, automation facilitates the creation of whitelists for low-risk clients, reducing redundant checks and expediting onboarding. Check out our Guide to KYC Automation for more information.

Does your organisation need a KYC Analyst?

A dedicated KYC Analyst or compliance team is essential to effectively executing all tasks within your KYC checklist. Professional expertise ensures meticulous customer verification, risk assessment, and compliance. How do you plan on navigating the ever-changing KYC landscape? Outsourcing to managed service providers is one of the most effective ways to keep on top of your KYC resource requirements, while keeping pace with the latest KYC regulations. At FDM, we offer businesses AML-KYC PODs, agile teams that deliver maximum impact. Partner with us and benefit from specially-trained KYC Analysts with the skills and up-to-date best practices to lead your KYC operations to long-term success.

Get in touch to find out more about FDM’s AML-KYC PODs.