Service

KYC & Customer Due Diligence Remediation

Are our customer files defensible?

Strengthen your customer files before they become regulatory findings.

Independent support for KYC remediation programmes, customer due diligence reviews and financial crime file remediation, designed to improve quality, consistency and regulatory confidence.

The Challenge

The question behind the engagement.

Customer due diligence is one of the most closely scrutinised areas of every financial crime framework.

Over time, customer files can become inconsistent as regulatory expectations evolve, risk methodologies change and documentation standards improve.

Many firms carry historic customer populations that no longer meet today's expectations. Missing information, outdated documentation, inconsistent risk ratings and incomplete source of funds or beneficial ownership records can all increase regulatory risk.

Whether driven by internal audit, regulatory findings, business growth or changing legislation, remediation programmes require careful planning, clear governance and a proportionate, risk-based approach.

How we help

Judgement, not a checklist.

We read your existing customer files across the highest-risk cohorts, identify the missing or outdated information, agree the additional documentation the file needs and work through beneficial ownership, source of funds and source of wealth where the existing record will not stand up to challenge.

We agree the file-closure standard with the MLRO, set the QA sampling rate, review completed files on a sampling basis and feed the recurring quality issues back into reviewer guidance so the same gaps do not keep reappearing.

We sit on the programme governance meetings, answer the implementation questions reviewers escalate, approve the harder customer decisions and provide senior management with reporting that shows where file quality stands, not just how many files have been touched.

The Result

After the engagement.

The Result
  • Customer Population Assessment
  • File Quality View
  • Gap Analysis
  • Remediation Strategy
  • Risk-Based Prioritisation
  • Governance Framework
  • Quality Assurance Approach
  • Executive Reporting
Engagement snapshot
Who it's for
  • Payment Institutions
  • Electronic Money Institutions
  • Investment Firms
  • Asset Managers
  • Wealth Managers
  • Crypto Asset Service Providers
  • Corporate Service Providers
Typical duration
From four weeks to several months depending on programme size.
Delivery
Remote, on-site or hybrid.
Primary output
Structured remediation programme with governance, oversight and practical recommendations.
Ideal when
Preparing for regulatory reviews, improving file quality or managing large-scale customer remediation.
Key Takeaways
  • 01We read your existing customer files across the highest-risk cohorts, identify the missing or outdated information, agree the additional documentation the file needs and work through beneficial ownership, source of funds and source of wealth where the existing record will not stand up to challenge.
  • 02We agree the file-closure standard with the MLRO, set the QA sampling rate, review completed files on a sampling basis and feed the recurring quality issues back into reviewer guidance so the same gaps do not keep reappearing.
  • 03We sit on the programme governance meetings, answer the implementation questions reviewers escalate, approve the harder customer decisions and provide senior management with reporting that shows where file quality stands, not just how many files have been touched.
Frequently asked questions

A few considered answers.

Begin a conversation

Ready to strengthen your customer files?

Well-planned remediation reduces regulatory risk while improving the quality and consistency of customer due diligence.