Onboarding

Spec sheet // Glossary // ONBOARDINGRev 2026.10
Glossary / O / Onboarding
Glossary · KYC and identity

Onboarding

Also called customer onboarding, client onboarding

Definition

Onboarding is the process a regulated firm follows to take on a new customer. It collects and verifies identity, screens the customer against sanctions and politically exposed person lists, assesses money laundering risk and opens the account. Anti-money laundering rules require most of these checks before the business relationship starts.

COLLECTVERIFYSCREENRISK RATEAPPROVE
Fig. 1 · Onboarding
MLR 2017, reg 28 · AMLD4, Article 13 · CIP Rule
Key rulesMLR 2017, reg 28 · AMLD4, Article 13 · CIP Rule · FinCEN CDD Rule
Applies toUK banks, payment firms, accountants, lawyers and other relevant persons
RegionsUK · EU · US · Global
01

How it works

Retail onboarding is now largely digital and can take minutes. A customer submits details and an identity document, completes a selfie check, and is screened automatically. Business onboarding takes longer. Firms must identify beneficial owners, understand the ownership structure and the nature of the business, and verify company records. Higher-risk customers trigger enhanced due diligence, including source of funds checks.

Onboarding sets the customer's first risk rating, which drives later monitoring and review cycles. Rules in the UK, EU and US require verification before or during the establishment of the relationship, with narrow exceptions. Firms balance speed against control. Failures at onboarding, such as accepting mule accounts or missing beneficial owners, are a frequent finding in enforcement actions.

Step 1CollectGather customer data, documents and ownership details.
Step 2VerifyConfirm identity and beneficial owners from reliable sources.
Step 3ScreenCheck sanctions, PEP and adverse media lists.
Step 4Risk rateAssign a customer risk rating and due diligence level.
Step 5ApproveOpen the account or escalate for senior sign-off.
02

The rules

UK · 26 June 2017MLR 2017, reg 28Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 28

Requires firms to identify and verify customers and beneficial owners, and to conduct ongoing monitoring including scrutiny of transactions throughout the relationship.

UK banks, payment firms, accountants, lawyers and other relevant persons
EU · 26 June 2017AMLD4, Article 13Directive (EU) 2015/849 on the prevention of the use of the financial system for money laundering or terrorist financing

Requires customer identification and verification from reliable independent sources, and ongoing monitoring of the business relationship including scrutiny of transactions.

EU credit and financial institutions and other obliged entities
US · 1 October 2003CIP RuleCustomer Identification Program rule, 31 CFR 1020.220

Requires a written programme to collect name, date of birth, address and identification number, and to verify identity within a reasonable time.

US banks and other covered financial institutions
US · 11 May 2018FinCEN CDD RuleCustomer Due Diligence Requirements for Financial Institutions, 31 CFR 1010.230 and 1020.210

Requires identifying beneficial owners of legal entity customers, understanding the relationship and ongoing monitoring to report suspicious transactions and update customer information.

US banks, broker-dealers, mutual funds, futures commission merchants
03

Common questions

How long does customer onboarding take?

Simple retail onboarding can be completed in minutes with automated checks. Corporate and institutional onboarding often takes days or weeks because firms must verify ownership structures, beneficial owners and the purpose of the relationship.

Can an account be opened before checks are finished?

UK and EU rules allow verification to be completed during the establishment of a relationship in limited cases where risk is low. Bank accounts may be opened before verification is complete, but no transactions can be carried out until it is.

What is the difference between onboarding and KYC?

KYC is the set of customer due diligence checks. Onboarding is the wider process of taking on a customer, which includes KYC alongside account set-up, product eligibility checks, terms acceptance and internal approvals.