Perpetual KYC replaces the periodic review, where every file is refreshed on a one, three or five year cycle, with a continuous one: records are re-checked against their sources on a schedule or when an event suggests a change, such as a new director filed at the registry, a change of registered address, a sanctions list update or a media report. Files that have not changed need no analyst time; files that have are routed for review.
What the rules require
Schedule 2 of the AMLO requires ongoing monitoring of the business relationship and that the documents, data and information obtained in customer due diligence are kept up to date and relevant, with reviews of existing records at appropriate times and in particular for higher-risk customers. The HKMA's guideline ties the review frequency to risk. Neither prescribes perpetual KYC, but both are satisfied by it, and the regulators have encouraged regtech that keeps records current.
Why it matters
A periodic review finds a change months after it happened, and the review itself becomes a backlog. Checking the registry when the registry changes is cheaper and leaves a record of the date each fact was last confirmed.
How Fill Easy relates to it
Monitoring and remediation is the batch form: send the client book as an Excel file to remediation@fill-easy.com, and every entity is re-checked at its registry with director, shareholder, address and status changes flagged field by field. Run it on the cycle your policy sets, or more often for the higher-risk segment. Through the API, the same searches can be scheduled from your own system, which is perpetual KYC in practice.