Perpetual KYC: Innovation delivers near-real time Risk Management
By Frank Cummings, CEO of AML Partners
Perpetual KYC has arrived, and we all are cheering. Not because it replaces the process of Periodic Review—it doesn’t. But Perpetual KYC can—and will—supercharge your Risk Management and your readiness for quick and effective Periodic Reviews.
Perpetual KYC leverages the rapid advances in RegTech software solutions for AML Compliance and GRC. Our RegTech compliance platform, for example, achieves Perpetual KYC by integrating it into automated no-code workflows. For AML Compliance risk management, we focus on three key elements: data import, screening, and risk monitoring. The following describes how each elevates and automates your Risk Management on our RegTechONE platform for AML Compliance:
Perpetual Data Interface
Standard RegTechONE installations include data interfaces to the data sources each user-institution prefers. Some of the larger and more innovative data vendors have developed processes to keep their data always up to date.
Dun and Bradstreet offers a good example. Institutions that use RegTechONE with a Dun and Bradstreet data subscription maintain near-real-time ownership information via four options that may be mixed-and-matched depending on Risk:
- Bulk-Update Seeding–This process allows users to seed their entire KYC collection with D&B data.
- User-Submitted Updates–When an end-user submits a client to ad hoc screening in RegTechONE, the platform automatically sends a request to D&B to update that client’s data.
- Periodic Review/KYC Refresh – This option runs automatically at the beginning of a periodic review. This ensures that the file is completely up to date with data interfaces and Risk.
- Push Updates – This option provides near-real time updates of all your D&B data.
Today’s powerful RegTech software solutions for AML Compliance provide this range of options to end-users. Compliance professionals in each institution choose the options that best suit their Risk-based Approach and book of business. With data imports on an AML Compliance platform, the power of Perpetual KYC can be flexed to meet the precise requirements of each institution’s Risk profile.
Perpetual Sanctions, Negative News and PEP Screening
RegTechONE users also leverage a “perpetual” approach to Sanctions, Negative News, and PEP Screening. Major data vendors provide both full seed-data lists and also regular delta lists (i.e. lists with changes from the seed data). Institutions that use RegTechONE with a LexisNexis subscription maintain near-real-time screening data for Sanctions, Negative News, and PEPs. Following are more details on this process:
When an institution uses the RegTechONE platform for name screening during the on-boarding process, their platform installation includes our Holistic Screening Engine. Our Holistic Screening Engine (or HSE) pulls down a complete LexisNexis data file. The HSE automatically ingests the file and prepares it for screening requests.
Screening in RegTechONE for on-boarding can now begin. During the on-boarding workflow, users can input the required information and configure which fields are to be screened with what lists. Once complete, any concerning finds are presented in a case-management workflow.
Every night, the HSE importer automatically checks with LexisNexis to identify list updates and pull them down. Once changes have been ingested in the HSE, RegTechONE automatically initiates a full database scan to identify all customers and principles affected by the LexisNexis changes. And for repeated hits with no changes in the LexisNexis list, RegTechONE automatically de-dupes them; only cases with new hits will be presented for resolution.
Perpetual Risk Monitoring (Near-Real Time)
RegTechONE users also leverage a “perpetual”—i.e. near-real time–approach to Risk Monitoring. Every institution wrestles with the problem of additional data being imported into a customer record after Risk has been assessed. For example, additional PEPs or Negative News could surface during perpetual screening. RegTechONE users choose through configuration whether and how the platform automates Perpetual Risk Monitoring.
For example, when additional Risk-relevant data appears, RegTechONE can automatically recalculate Risk for that customer. And if RegTechONE’s automatic Risk-recalculation raises pre-configured concerns, RegTechONE removes that customer’s approved status and sends a pre-configured email to the proper user(s) to determine any further actions. When the user opens the customer record on RegTechONE, all derived Risk actions are run to complete the risk picture.
Perpetual KYC: Next-level Near-real-time Innovation
Perpetual KYC capabilities on our RegTechONE platform transform users’ access to near-real time intelligence crucial to Risk Management and AML Compliance. For AML Partners and RegTechONE, Perpetual KYC monitoring encompasses automated integration of three areas: Data Import, Screening, and Risk. And while Perpetual KYC does not replace Risk-Based Periodic Review/Refresh of your KYC files, Perpetual KYC automates and integrates the work of Periodic Review to achieve low-touch near-real time accuracy with extraordinary efficiency.