KYC remediation

Bringing an existing book of customer files up to the current standard: re-checking each customer at source and fixing missing or stale data.

KYC remediation is a project to repair existing files rather than onboard new ones. It follows a regulator's finding, an internal audit, a change in the rules, a merger that brings in another firm's book, or the discovery that a system migration lost data. Each file is compared with the current requirement, the gaps are listed, and each gap is closed by obtaining the evidence: a fresh registry search, an identity re-verified, a beneficial owner traced, a source of wealth documented.

What the rules require

Schedule 2 of the AMLO requires a firm to keep its customer due diligence information up to date and to review existing records, and it applies the due diligence measures to existing customers when a review is due or when the firm doubts what it holds. The HKMA's guideline expects a firm to remediate deficiencies within a reasonable time and to apply a risk-based order, starting with the higher-risk customers. Enforcement decisions in Hong Kong have cited slow or incomplete remediation.

Why it matters

Remediation is measured in files per analyst per day. The slow part is obtaining documents from many registries in many formats, and the error-prone part is re-keying what comes back. A remediation that stalls becomes a second finding.

How Fill Easy relates to it

Monitoring and remediation takes the book as one Excel file sent to remediation@fill-easy.com, one row per entity with your reference, and returns it with every entity re-checked at its registry and the changes flagged. Thousands of entities can go in one run, mixing Hong Kong, Mainland China, BVI, Cayman and international companies. Price and turnaround are confirmed when the file is sent, before the run starts. The mailbox page shows how a file is handled.

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