Perpetual KYC

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Glossary · KYC and identity

Perpetual KYC

pKYCAlso called continuous KYC, event-driven review, dynamic KYC

Definition

Perpetual KYC is an approach to customer due diligence in which a firm updates customer records when something changes, rather than waiting for a scheduled periodic review. Data feeds and triggers flag events such as new owners, sanctions designations or unusual activity, prompting a targeted review of that customer.

REGISTRY CHANGESANCTIONS UPDATEUNUSUAL ACTIVITYRISK RE-RATED
Fig. 1 · Perpetual KYC
MLR 2017 reg 28(11) · CDD Rule · AMLR Art 26
Key rulesMLR 2017 reg 28(11) · CDD Rule · AMLR Art 26
Applies toRelevant persons under the MLRs
RegionsGlobal
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How it works

A bank running perpetual KYC links customer files to external and internal data. Company registry changes, sanctions and PEP list updates, adverse media and transaction behaviour all act as triggers. When a trigger fires, the system refreshes the risk rating and routes the case to an analyst if needed. Low-risk customers with no events may see fewer manual reviews.

The approach matters because periodic reviews leave files out of date for years between cycles. AML rules require ongoing monitoring and keeping CDD information current, without prescribing a calendar. Event-driven updates let firms show supervisors that risk ratings reflect the customer today. The shift depends on data quality, clear trigger definitions and audit trails showing why each review happened.

Step 1Connect dataLink customer files to registries, watchlists and transaction data.
Step 2Define triggersSet events that should prompt a customer review.
Step 3Refresh ratingRecalculate the customer risk rating when a trigger fires.
Step 4Review casesAnalysts assess material changes and update the file.
Step 5Log decisionsKeep an audit trail of each trigger and outcome.
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The rules

UK · 26 June 2017MLR 2017 reg 28(11)Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, regulation 28(11)

Requires ongoing monitoring of business relationships, including keeping customer due diligence documents, data and information up to date.

Relevant persons under the MLRs
US · 11 May 2018CDD RuleFinCEN Customer Due Diligence Requirements for Financial Institutions, 31 CFR 1020.210(b)(5)

Requires ongoing monitoring to identify suspicious transactions and, on a risk basis, to maintain and update customer information.

Banks and other covered financial institutions
EU · 10 July 2027AMLR Art 26Regulation (EU) 2024/1624, Article 26 on ongoing monitoring

Requires ongoing monitoring of business relationships and updating of customer information, with reviews at frequencies linked to the customer's risk.

Obliged entities in the EU
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Common questions

Do regulators require perpetual KYC?

No rule names perpetual KYC. AML rules require ongoing monitoring and up-to-date customer information. Perpetual KYC is one way firms meet that requirement, using event triggers instead of relying only on fixed review cycles.

Does perpetual KYC remove periodic reviews?

Not entirely. Many firms keep periodic reviews for high-risk customers or as a backstop. Event-driven updates reduce the number of reviews that find nothing new and focus analyst time on customers whose circumstances have changed.

What events typically trigger a pKYC review?

Common triggers include changes in ownership or directors at a company registry, new sanctions or PEP matches, adverse media, and transaction activity that departs from the expected profile. Each firm sets its own triggers through its risk assessment.