Evaluates customer identification and verification documentation against CIP/CDD/EDD requirements. Use when reviewing KYC files, validating customer identification, or assessing customer risk.
Scanned 9/12/2026
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---
name: reviewing-kyc-documentation
language: en
description: Evaluates customer identification and verification documentation against CIP/CDD/EDD requirements. Use when reviewing KYC files, validating customer identification, or assessing customer risk.
tags:
- review
- financial-compliance
- risk
metadata:
author: casemark
practice_areas:
- Regulatory Compliance
- Financial Regulation
- Compliance
document_types:
- Review Report
skill_modes:
- Review
- Analysis
---
# Reviewing KYC Documentation
Evaluates customer identification and verification documentation against Customer Identification Program (CIP), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) requirements to determine whether a KYC file is complete, accurate, and risk-appropriate.
## When To Use
- Reviewing a new customer onboarding file before account opening approval
- Periodic re-review of existing customer KYC files (annual, trigger-based, or risk-cycle)
- Assessing whether a customer risk rating change requires EDD uplift
- Auditing a portfolio of KYC files for regulatory exam readiness
- Evaluating remediation files flagged by compliance monitoring
## Inputs To Gather
- **Customer identification documents**: government-issued ID (passport, driver's license, national ID), articles of incorporation, certificate of formation, or trust instrument for entities
- **Verification records**: documentary vs. non-documentary verification method used; third-party verification results (e.g., LexisNexis, World-Check, Dow Jones)
- **Beneficial ownership declaration**: ownership structure chart, UBO identification form, percentage thresholds applied [VERIFY: 25% threshold under CDD Rule; jurisdiction may differ]
- **Risk rating worksheet**: initial and current risk score, scoring methodology, risk factors applied
- **Source of funds / source of wealth documentation**: bank statements, tax returns, business financials, or self-certification
- **Screening results**: OFAC/SDN, PEP databases, adverse media, sanctions lists — with date of last screening
- **Account activity profile**: expected transaction types, volumes, jurisdictions, and any deviations flagged post-opening
- **Prior review notes**: previous findings, remediation status, outstanding deficiencies
## Workflow
1. **Confirm file completeness** — Check that all required CIP elements are present for the customer type:
- Individuals: name, date of birth, address, government ID number [VERIFY: specific ID requirements vary by jurisdiction]
- Legal entities: legal name, formation jurisdiction, principal place of business, EIN/TIN, formation documents
- Trusts/other structures: trust agreement, trustee identification, beneficiary information where required
2. **Validate identification and verification** — Assess whether:
- Documentary verification uses unexpired, legible, government-issued documents
- Non-documentary methods (database checks, credit bureau, references) are adequately documented
- Discrepancies between ID documents and application data are noted and resolved
- For entities: verify legal existence through formation documents or registry searches
3. **Assess beneficial ownership compliance** — Confirm:
- All individuals owning 25% or more are identified with full CIP-level information [VERIFY: threshold per CDD Final Rule; some jurisdictions use 10% or 20%]
- A single individual is identified as having significant management control
- Ownership structure is diagrammed for multi-layered entities
- Nominee/bearer share arrangements are flagged and investigated
4. **Evaluate risk rating** — Review the assigned risk level against:
- Customer type (individual, corporate, PEP, MSB, NBFI, charity/NPO)
- Geographic risk (FATF high-risk jurisdictions, sanctioned countries, tax havens)
- Product/service risk (correspondent banking, private banking, trade finance, virtual assets)
- Transaction risk (expected volume, cash intensity, cross-border activity)
- Confirm the risk rating methodology matches institutional policy and that the score is correctly calculated
5. **Review EDD where applicable** — For high-risk customers, verify:
- Source of wealth and source of funds are independently documented (not just self-declared)
- Senior management approval for relationship establishment or continuation is on file
- Enhanced monitoring parameters are defined (transaction thresholds, review frequency)
- Negative news and PEP screening performed at closer intervals
6. **Check screening and ongoing monitoring** — Confirm:
- OFAC/sanctions screening was run at onboarding and is current
- PEP screening covers the customer and all beneficial owners
- Adverse media screening is documented with disposition of hits
- Screening is re-run at each periodic review and upon trigger events
7. **Classify findings** — Assign severity to each deficiency:
- **Critical**: missing CIP element, unresolved sanctions hit, no beneficial ownership on file
- **Major**: expired identification document, risk rating inconsistent with profile, EDD not performed for high-risk customer
- **Minor**: formatting gaps, outdated contact information, missing secondary documentation
## Output
Produce a structured KYC review report containing:
- **File summary**: customer name, account number, customer type, risk rating, review date, reviewer
- **Completeness checklist**: pass/fail for each CIP, CDD, and EDD element
- **Findings table**: finding description, severity (Critical/Major/Minor), regulatory reference, evidence citation
- **Remediation recommendations**: specific corrective action for each finding, responsible party, deadline
- **Overall assessment**: file status recommendation — Satisfactory, Conditional (with remediation required), or Unsatisfactory (escalation required)
- **Escalation flags**: any findings requiring SAR consideration, account restriction, or senior management review
## Quality Checks
- Every finding cites a specific regulatory requirement or internal policy section (e.g., 31 CFR 1020.220, BSA/AML Manual Section X) [VERIFY: cite institution-specific policy references]
- Beneficial ownership analysis accounts for all layers of the ownership chain, not just the first tier
- Risk rating review confirms arithmetic accuracy and that all applicable risk factors were scored
- Screening results include date stamps — reject any screening older than the institution's policy window [VERIFY: typical policy is 30-90 days; confirm institutional standard]
- No finding is marked "Minor" if it would independently constitute a regulatory violation
- Flag any assumption or unverifiable data point with [VERIFY] rather than presenting it as confirmed
- If the file involves a jurisdiction, product, or customer type outside the reviewer's expertise, escalate to specialized compliance staff
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