Perpetual KYC: does event-driven refresh fix KYC drift?

TL;DR: Perpetual KYC replaces fixed review cycles with event-driven customer due diligence refreshes, according to OneID, so records update when address, ownership, transaction patterns or screening results change. The model is a way to satisfy ongoing-monitoring duties without letting customer files go stale between annual review peaks.

Editorial analysis by NHI Mgmt Group, based on content published by OneID: “Perpetual KYC (pKYC): Keeping Customer Due Diligence Current”.

Key questions

Q: How should firms decide which KYC changes deserve an immediate refresh?

A: Use a risk-based trigger model.

Q: When does periodic KYC review fail in practice?

A: It fails when the review cycle is too slow for the pace of customer change.

Q: Should organisations prioritise remediation or perpetual KYC first?

A: Remediation should come first when the existing book is already inconsistent or heavily backlogged.

Practitioner guidance

• Define governed trigger lists Set out which customer events require a KYC refresh, how each trigger is risk-ranked, and what review depth follows from each rank.
• Separate record currency from transaction monitoring Assign identity re-checks to the customer file and keep transaction scrutiny in the monitoring function so the two controls are not conflated.
• Use remediation before perpetual operation Clean the back-book first, then move to event-driven refresh so pKYC does not inherit a backlog of stale or inconsistent records.

Bottom line: Perpetual KYC is an operating model for keeping customer records current, not a new legal duty or a replacement for ongoing monitoring.

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