Re-KYC and restrictions
Periodic review (Re-KYC)
Section titled “Periodic review (Re-KYC)”The review cycle follows the risk level. The defaults are the guideline ceilings: High every 365 days, Medium every 730, Low every 1,095. An institution can set shorter cycles. The database refuses longer ones.
- A review opens at least 60 days before the due date.
- Messages go out between 08:00 and 20:00, in the institution’s name and through its own e-mail and SMS providers. Each message records its result: sent, failed after three tries, or not sent with a reason (for example, the review was already finished).
- The day after the due date, an overdue-review restriction opens and the account becomes Exit-Only: the customer can sell or withdraw, nothing else.
- When the customer replies, an officer records the answer and the review goes through sign-off. Officers can also run reviews in bulk.
Restrictions
Section titled “Restrictions”Every account has four legs: deposit, withdraw, buy and sell. A restriction closes one or more legs, and so does releasing it: nothing is all-or-nothing by accident.
- Restrictions open from an overdue review, a confirmed match, a letter from an authority or an officer’s decision.
- Releasing a restriction follows its own unlocking rules and sign-off.
- Each order is tracked against what was actually done. For a DA Dealer, the trading system confirms execution back to CDD Core.