Re-KYC
Every customer is reviewed on a cycle set by their risk level. The system opens the review at least 60 days ahead, reminds the customer on a fixed ladder, and restricts the account to Exit-Only the day after the due date if nothing comes back. Officers record the reply and sign the result on a route set by the outcome.
Who may do it: Maker (record the reply, propose the result) · Checker and Approver (sign by outcome) · Compliance Officer, Head of Compliance and Internal Audit (read).
Cycles
Section titled “Cycles”High every 365 days, Medium every 730, Low every 1,095. These are the guideline ceilings: an institution may set shorter cycles, which QX applies on the institution’s written request, and the database refuses longer ones. A change applies to each customer from their next review; nobody is moved silently.
The ladder
Section titled “The ladder”| When | What the system does |
|---|---|
| Due − 60 days | Opens the review; e-mail notice and first SMS |
| Due − 30 days | Second reminder by SMS and e-mail |
| Due − 7 to due − 1 | Daily reminders by SMS and e-mail |
| Due + 1 day | Overdue-review restriction: the account is Exit-Only |
Messages go out between 08:00 and 20:00, in the institution’s name, through its own e-mail and SMS providers. Each records its result: sent, failed after three tries, or not sent with the reason.
The 60-day guarantee. When a level changes and the new due date is already past or less than 60 days away, nothing is restricted at once: the ladder starts that day and the cut-off moves to 60 days plus one. The cycle itself is not lengthened.
- When the customer replies, an officer records the reply. If the customer updated their data, it is re-screened and re-scored before the Maker looks.
- Maker claims the review and proposes the result.
- The signers on the route sign.
| Outcome | Signed by |
|---|---|
| Level unchanged · Low → Medium · result Low | Checker |
| Result High (from Low or Medium) | Checker, then Approver (EDD path) |
| High → Medium | Approver |
The next due date counts from the day the review is completed, never from the old due date.
Bulk review
Section titled “Bulk review”A review qualifies for bulk only when every returned field matches the data held, the level is Medium before and after, and no weak hit is outstanding. The system decides; no officer can mark a review for bulk. The Maker proposes and the Checker approves up to 50 at once with Select first N and Approve N; each customer still gets its own row in the trail.
DA Dealer edition
Section titled “DA Dealer edition”The review also re-assesses suitability, re-checks the knowledge test where the customer’s class changed, and re-runs the suspicious-pattern checks at every periodic review.
What the system does or refuses
Section titled “What the system does or refuses”- Frozen or restricted accounts leave the review population — no reminders while a state authority holds the account. After release, the next review date counts from the release.
- No cycle longer than the ceiling.
- The proposer cannot sign the same review, in bulk or one at a time.