KYC and CDD Customer Profile Template (EU AMLR, US CDD Rule)
KYC customer profile: legal basis, identification, verification, beneficial ownership chart, purpose and nature, source of funds, expected activity, PEP and sanctions screening, risk rating, decision, periodic review
使用方法: Use it when onboarding or refreshing a customer and you need one record proving who the customer is, who owns it and what activity to expect. Fill identification, verification and beneficial ownership first, then purpose, expected activity and screening before the decision. The main pitfall is an expected activity profile so vague that monitoring can never detect a deviation.
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KYC and CDD Customer Profile: [Customer name]
Customer due diligence (CDD) profile for one customer relationship: identification and verification of the customer and the people acting for it, beneficial ownership and control, purpose and intended nature of the relationship, source of funds and expected activity, politically exposed person (PEP), sanctions and adverse media screening, customer risk rating, the due diligence decision and the ongoing monitoring and periodic review record. Based on FATF Recommendations 10, 12 and 24 (cited by number and title), the US Customer Identification Program rule (31 CFR 1020.220) and CDD Rule (31 CFR 1010.230), the current EU framework (Directive (EU) 2015/849 as transposed in national law) and the EU Anti-Money Laundering Regulation, Regulation (EU) 2024/1624 (AMLR), which applies from 2027-07-10, and the UK Money Laundering Regulations 2017, as of 2026-10. Replace every
[bracketed]value and every row marked Example. This is a document format, not legal, compliance or regulatory advice. Obtain the standard or law for the normative text and check current local law.
Document control
| Field | Value |
|---|---|
| Document ID | [KYC-YYYY-NNNNN] (Example: KYC-2026-01482) |
| Customer ID | [Core banking customer number] |
| Customer legal name | [Name] (Example: Quillmere Marine Supplies B.V.) |
| Relationship type | [Retail / SME / Corporate / Financial institution / Private banking] |
| Booking entity | [Legal entity and branch] (Example: Fernhollow Bank, head office) |
| Version | [1.0] |
| Status | [Draft / Pending approval / Approved / Under review / Exited] |
| Owner | [@relationship-manager] |
| Approvers/reviewers | [@kyc-analyst], [@kyc-quality-checker], [@approver per matrix] |
| CDD level applied | [Simplified / Standard / Enhanced] |
| Risk rating | [Low / Medium / High] (see section 8) |
| Linked records | [EDD memo ID], [screening case IDs], [credit file ID] |
| Last updated | YYYY-MM-DD |
| Next review due | YYYY-MM-DD (see section 10) |
| Classification | Confidential: customer due diligence record, need-to-know |
Approvals
| Role | Name | Decision | Date |
|---|---|---|---|
| KYC analyst (preparer) | [@name] | [Complete] | YYYY-MM-DD |
| KYC quality checker | [@name] | [Pass / Return with comments] | YYYY-MM-DD |
| Approver (per risk matrix) | [@name] | [Approve / Approve with conditions / Decline] | YYYY-MM-DD |
| Senior management (high risk, PEP) | [@name] | [Approve / Decline] | YYYY-MM-DD |
Revision history
| Version | Date | Author | Change summary |
|---|---|---|---|
| 1.0 | YYYY-MM-DD | [@name] | Onboarding profile |
| 1.1 | YYYY-MM-DD | [@name] | Example: Trigger review after change of shareholder |
| 2.0 | YYYY-MM-DD | [@name] | Example: Periodic review, risk rating confirmed Medium |
Contents
- Scope and legal basis
- Customer identification
- Identity verification
- Beneficial ownership and control
- Purpose and intended nature of the relationship
- Source of funds and expected activity
- Screening: PEP, sanctions and adverse media
- Customer risk rating
- Due diligence decision and conditions
- Ongoing monitoring and periodic review
- Records, data protection and confidentiality
- Glossary and references
- Standard and licence note
1. Scope and legal basis
This profile records the customer due diligence performed on one
customer by [Institution name]. It covers the measures that every
customer receives (identification, verification, beneficial ownership,
purpose and nature, ongoing monitoring) and records whether any
simplified or enhanced measures were applied. The institution's AML/CFT
policy (AML/CFT Programme Policy, compliance/aml-cft-programme-policy)
sets the standard; this file shows that the standard was met for this
customer.
Use the table below to record the rules that apply to the booking entity. Keep the AMLR rows even before 2027-07-10 so that the profile can be refreshed without a format change when the regulation applies.
| Jurisdiction | Rule (as of 2026-10, check local law) | Topic in this profile | Status |
|---|---|---|---|
| International | FATF Recommendation 10 (Customer due diligence) | Sections 2 to 6, 10 | Standard, implemented through national law |
| International | FATF Recommendation 12 (Politically exposed persons) | Section 7 | Standard |
| International | FATF Recommendations 24 and 25 (Transparency and beneficial ownership of legal persons and of legal arrangements) | Section 4 | Standard |
| EU (current) | Directive (EU) 2015/849 as amended, Arts 13 (CDD measures), 14 (timing), 18 to 24 (enhanced due diligence, PEPs), 40 (records), as transposed in [Member State] law | All | In force until 2027-07-09 via national law |
| EU (from 2027-07-10) | Regulation (EU) 2024/1624 (AMLR): Art. 19 (when to apply CDD), Art. 20 (CDD measures), Art. 22 (identification data), Art. 23 (timing of verification), Art. 25 (purpose and intended nature), Art. 26 (ongoing monitoring and update periods), Arts 51 to 55 (beneficial owners of legal entities), Art. 77 (record retention) | All | Applies from 2027-07-10 (Art. 90) |
| EU (pending) | AMLA regulatory technical standards on CDD information under AMLR Art. 28 | Sections 2 to 6 | Final draft submitted to the Commission in 2026-10; not yet adopted, check status |
| US | 31 CFR 1020.220 (Customer Identification Program for banks) | Sections 2, 3, 7, 11 | In force |
| US | 31 CFR 1010.230 (beneficial ownership of legal entity customers) | Section 4 | In force; FinCEN exceptive relief order of 2026-02-13 limits re-identification at each new account (optional, check order) |
| US | 31 CFR 1020.210 (AML programme including risk-based ongoing CDD) | Sections 8, 10 | In force; FinCEN programme NPRM of 2026-04-07 is a proposal only |
| UK | Money Laundering Regulations 2017 (SI 2017/692), regs 27 to 31 (CDD), reg. 5 (beneficial owner of body corporate), regs 33 and 35 (EDD, PEPs) | All | In force, check amendments |
2. Customer identification
Record the customer's identifying data exactly as it appears in the source document or register. Where the customer is a legal entity, identify the entity itself, its legal representatives and every person who will act on its behalf, and confirm their authority. Where the customer is a natural person, record the data for the individual and for any attorney or guardian.
The minimum data differs slightly by jurisdiction. The US CIP rule requires name, date of birth (individuals), address and an identification number before account opening. The AMLR lists a wider data set from 2027-07-10, including all names, place and date of birth, nationalities and, for legal entities, the Legal Entity Identifier where available. Collect the wider set when the booking entity is in the EU, so that the profile is ready for the regulation.
2.1 Legal entity customer
| Field | Value |
|---|---|
| Registered legal name | [Name] (Example: Quillmere Marine Supplies B.V.) |
| Trading names | [Names] (Example: Quillmere Marine) |
| Legal form | [Form] (Example: private limited company) |
| Country of incorporation | [Country] (Example: Netherlands) |
| Registration number | [Number] (Example: 00000000, fictional) |
| Legal Entity Identifier (LEI) | [LEI or "none"] |
| Tax identification number | [TIN] |
| Registered office | [Address] |
| Principal place of business (if different) | [Address] |
| Date of incorporation | YYYY-MM-DD (Example: 2014-03-11) |
| Industry and activity code | [NACE / NAICS code and description] (Example: wholesale of marine hardware and safety equipment) |
| Listed or regulated status | [Exchange and ticker / Regulator and licence / None] |
| Website and public footprint | [URL] |
2.2 Legal representatives and authorised persons
| ID | Name | Role | Authority source | Identified and verified |
|---|---|---|---|---|
| REP-001 (Example) | Ana Reyes-Lowe | Managing director | Commercial register extract, YYYY-MM-DD | Yes, see VER-002 |
| REP-002 (Example) | Halden Voss | Director and signatory | Board resolution of YYYY-MM-DD | Yes, see VER-003 |
| REP-003 (Example) | Nils Okafor-Brandt | Finance manager, online banking user | Mandate form, signed by REP-001 | Yes, see VER-004 |
2.3 Natural person customer (use instead of 2.1 for individuals)
| Field | Value |
|---|---|
| Full name and all surnames | [Name] |
| Date and place of birth | YYYY-MM-DD, [Place] |
| Nationalities | [All nationalities, or statelessness] |
| National identification number | [Number, where applicable] |
| Residential address | [Address] |
| Tax identification number and tax residence | [TIN, country] |
| Occupation and employer | [Occupation] |
3. Identity verification
Verify the identity of the customer, each legal representative, each authorised person and each beneficial owner using reliable and independent sources. For legal entities, an official register extract dated close to onboarding is the usual primary source; for individuals, a government-issued identity document or an electronic identification means at a sufficient assurance level. Where a document is checked remotely, record the liveness and document authenticity checks.
Record discrepancies and how they were resolved. Under the US CIP rule the record must describe the documents relied on, the non-documentary methods used and the resolution of any substantive discrepancy. Under EU law, discrepancies between the information you hold and a central beneficial ownership register must be reported to the register authority (AMLR Art. 24 from 2027-07-10; national law today).
| ID | Subject | Method | Source and reference | Date | Result |
|---|---|---|---|---|---|
| VER-001 (Example) | Quillmere Marine Supplies B.V. | Register extract | Commercial register, extract no. [ref] | 2026-09-14 | Matches name, number, office, directors |
| VER-002 (Example) | REP-001 Ana Reyes-Lowe | Remote ID: passport chip read and liveness check | [Remote onboarding provider], session [ref] | 2026-09-15 | Verified |
| VER-003 (Example) | REP-002 / BO-003 Halden Voss | In-person ID document check | National identity card, branch [code] | 2026-09-16 | Verified |
| VER-004 (Example) | REP-003 Nils Okafor-Brandt | Remote ID | [Provider], session [ref] | 2026-09-16 | Verified |
| VER-005 (Example) | BO-001 Mirela Strand | Certified copy of passport plus address proof | Certified by notary, YYYY-MM-DD | 2026-09-18 | Verified |
| VER-006 (Example) | BO-002 Tomas Ekhart | Electronic identification (eIDAS notified scheme, high assurance) | [Scheme], transaction [ref] | 2026-09-18 | Verified |
Discrepancy log:
| ID | Discrepancy | Resolution | Reported to register |
|---|---|---|---|
| DIS-001 (Example) | Register lists Strand Holding Ltd at a former address | Customer provided updated register filing dated 2026-09-20 | Not required (address only, register updated by customer) |
4. Beneficial ownership and control
Identify each natural person who ultimately owns or controls the customer, take reasonable measures to verify their identity and record how the ownership and control structure works. A beneficial owner may hold an interest through ownership or exercise control by other means, such as voting agreements, the right to appoint directors or family arrangements.
Thresholds differ by regime and must be applied as written in the law that binds the booking entity:
- US CDD Rule (31 CFR 1010.230(d)): each individual who directly or indirectly owns 25 percent or more of the equity interests (ownership prong), plus one individual with significant responsibility to control, manage or direct the entity (control prong). Certain entity types are excluded or subject to the control prong only.
- EU, current law: Directive (EU) 2015/849 treats a shareholding or ownership interest of more than 25 percent as an indication of ownership; check the national transposition, which may set a lower threshold.
- EU, AMLR from 2027-07-10: Art. 52 sets ownership of 25 percent or more of shares, voting rights or other ownership interest, with indirect holdings calculated by multiplying through the chain and adding all chains; Art. 53 covers control by other means; where no owner can be identified, the senior managing officials are recorded and the reason is documented. The Commission may set a lower threshold for categories of entity that present a higher risk (Art. 52(2)); check for delegated acts.
- UK MLR 2017, reg. 5: more than 25 percent of shares or voting rights, or control by other means.
Because the example below has three owners at exactly 30 percent, every regime above treats them as beneficial owners. A holding of exactly 25 percent would qualify under the US rule and the AMLR, but not under a "more than 25 percent" rule; record which test was applied.
Indirect ownership in the example is calculated as the product of the holdings along each chain:
so Mirela Strand holds 50% x 60% = 30% and Tomas Ekhart holds 50% x 60% = 30%. Together with Halden Voss (30% direct) and the trust (10%), the holdings sum to 100%.
| ID | Name | Nationality and residence | Direct % | Indirect % | Total % | Basis (ownership / control) | Verified | PEP |
|---|---|---|---|---|---|---|---|---|
| BO-001 (Example) | Mirela Strand | [Nationality], resident Malta | 0 | 30.0 | 30.0 | Ownership via Strand Holding Ltd | VER-005 | No |
| BO-002 (Example) | Tomas Ekhart | [Nationality], resident Netherlands | 0 | 30.0 | 30.0 | Ownership via Strand Holding Ltd | VER-006 | Yes, see section 7 |
| BO-003 (Example) | Halden Voss | [Nationality], resident Netherlands | 30.0 | 0 | 30.0 | Ownership, also director | VER-003 | No |
| CTL-001 (Example) | Ana Reyes-Lowe | [Nationality], resident Netherlands | 0 | 0 | 0 | Control prong / senior managing official | VER-002 | No |
Trust holding (10 percent): record the settlor, trustees, protector and beneficiaries or class of beneficiaries even though the trust is below the ownership threshold, because a trust layer is a complexity factor in the risk rating. Example: Lantern Trustees Ltd (fictional professional trustee) holds for the Corran Family Trust; beneficiaries are the descendants of a fictional settlor, none of whom holds any other interest in the customer.
| Question | Answer |
|---|---|
| Ownership structure understood and plausible for the business? | [Yes / No, explain] (Example: Yes; holding company used by two co-founders since 2018) |
| Nominee shareholders or directors? | [Yes / No] |
| Bearer shares or similar instruments? | [Yes / No] |
| Beneficial ownership register checked and consistent? | [Register, date, result] |
| Layers above two levels or in a high-risk third country? | [Yes / No] |
| US: certification of beneficial owners obtained (31 CFR 1010.230(b)) | [Yes / Not applicable] |
5. Purpose and intended nature of the relationship
Explain what the customer will use the relationship for and why the institution considers that use credible. The AMLR (Art. 25, from 2027-07-10) expects the institution, where necessary, to obtain information on the purpose and economic rationale, the estimated amount of activity, the source and destination of funds and the customer's business activity or occupation. Current national law and the US CDD programme requirement expect a comparable understanding to build a customer risk profile.
| Item | Customer's statement | Institution's assessment |
|---|---|---|
| Products requested | [Products] (Example: EUR and USD current accounts, SEPA and SWIFT payments, trade finance documentary collections, card acquiring) | [Assessment] (Example: Consistent with a wholesale distributor that imports from Asia and sells within the EU) |
| Business model | [Description] (Example: Buys marine safety equipment from manufacturers in South Korea and Türkiye, sells to chandleries and boatyards in the Netherlands, Germany and Denmark) | [Assessment] |
| Main counterparties | [Top suppliers and customers] | [Assessment] |
| Countries involved | [Countries] (Example: NL, DE, DK, KR, TR, MT) | [Assessment: any high-risk third country?] |
| Reason for choosing this institution | [Statement] (Example: Moving from another bank to obtain trade finance) | [Assessment] |
| Expected relationship length | [Years] |
Narrative conclusion: [Two or three sentences stating whether the purpose is clear, plausible and consistent with the customer's size and ownership.] Example: The customer is an established wholesale distributor with ten years of filed accounts. The requested products match its import and distribution model. The move from another bank is explained by a trade finance need; the previous bank's reference letter is on file.
6. Source of funds and expected activity
Record where the funds that will flow through the relationship come from and what volumes are expected. Source of funds describes the origin of the money used in the relationship (for a trading company, usually sales receipts and bank financing). Source of wealth describes how the beneficial owners accumulated their total wealth and is collected under enhanced due diligence; when it is needed, document it in the EDD memo and summarise it here.
| Item | Value |
|---|---|
| Primary source of funds | [Source] (Example: Customer receipts from EU trade buyers) |
| Secondary sources | [Source] (Example: Shareholder loan from Strand Holding Ltd, EUR 400,000, agreement dated 2025-11-03) |
| Evidence | [Documents] (Example: Filed 2025 financial statements, revenue EUR 18.4 million; aged receivables list) |
| Initial deposit and origin | [Amount and remitting account] |
| Source of wealth (EDD only) | [Summary or "not required"] (Example: Required for BO-002 as a PEP, see EDD-2026-0311) |
Expected activity profile (monthly, EUR):
| Activity | Expected count | Expected value | Main counterparties or countries |
|---|---|---|---|
| Incoming SEPA credit transfers (Example) | 180 | 1,450,000 | NL, DE, DK customers |
| Outgoing international transfers (Example) | 25 | 1,050,000 | Suppliers in KR and TR |
| Outgoing SEPA payments (payroll, rent, taxes) (Example) | 70 | 260,000 | NL |
| Cash deposits (Example) | 0 | 0 | Not expected; any cash is a deviation |
| Card acquiring settlements (Example) | 22 | 90,000 | Webshop sales, EU cardholders |
Annualised, the example inflows are 12 x (1,450,000 + 90,000) = EUR 18,480,000, consistent with filed revenue of EUR 18.4 million. Recompute this check whenever the profile is refreshed.
7. Screening: PEP, sanctions and adverse media
Screen every subject named in this profile against the sanctions lists
that bind the booking entity (UN, EU, national, and US OFAC lists where
the institution has US exposure or US dollar clearing), against a PEP
database and for adverse media. Sanctions screening must also consider
ownership and control: the AMLR (Art. 20(1)(d), from 2027-07-10)
requires checking whether designated persons control the customer or
hold more than 50 percent of it, and the US OFAC 50 percent rule treats
entities owned 50 percent or more in aggregate by blocked persons as
blocked. The sanctions procedure (compliance/sanctions-compliance-procedure)
sets matching rules and escalation.
A PEP is an individual entrusted with a prominent public function, and their family members and known close associates. Any PEP among the customer, beneficial owners or representatives requires senior management approval, measures to establish source of wealth and source of funds, and enhanced ongoing monitoring (FATF R.12; Directive (EU) 2015/849 Arts 20 to 23 via national law; AMLR Art. 42 from 2027-07-10; UK MLR reg. 35). A person who leaves a prominent function remains subject to risk-based measures for at least 12 months under the AMLR (Art. 45). These measures apply to domestic and foreign PEPs alike under EU and UK law. In the UK, reg. 35(3A) (inserted by SI 2023/1371 from 2024-01-10) makes a lower level of risk the starting point for a domestic PEP, which lightens the extent of EDD but does not remove it.
| ID | Subject | Screening type | Lists or sources and version | Date | Potential matches | Disposition |
|---|---|---|---|---|---|---|
| SCR-001 (Example) | Quillmere Marine Supplies B.V. | Sanctions | EU consolidated list, UN list, OFAC SDN (list dates on case) | 2026-09-18 | 0 | Clear |
| SCR-002 (Example) | Strand Holding Ltd | Sanctions and ownership | As SCR-001 | 2026-09-18 | 1 (name similarity) | False positive: different registration number and country, case SAN-2026-7781 |
| SCR-003 (Example) | BO-002 Tomas Ekhart | PEP | [PEP data provider] | 2026-09-18 | 1 | True match: domestic PEP, member of the national parliament since 2023-12; EDD required |
| SCR-004 (Example) | All individuals | Adverse media | [News database], search terms on file | 2026-09-19 | 2 articles | Not relevant: articles concern a sailing regatta sponsorship |
| SCR-005 (Example) | Top five suppliers | Sanctions | As SCR-001 | 2026-09-19 | 0 | Clear |
8. Customer risk rating
Rate the customer with the approved customer risk rating methodology
(compliance/customer-risk-rating-methodology). Record each factor
score, the weighted result, any automatic high-risk trigger and any
override. A PEP, a link to a high-risk third country identified by the
European Commission, or a correspondent relationship are typical
automatic triggers for enhanced due diligence; check your methodology
for the exact list.
The example applies the institution's approved methodology exactly as
written (Customer Risk Rating Methodology,
compliance/customer-risk-rating-methodology, sections 3 and 4): four
factor groups scored 1 to 4, group weights customer 35%, geography 25%,
product 25% and channel 15%, and bands Low 1.00 to 1.79, Medium 1.80 to
2.59 and High 2.60 to 4.00. The group score is the sub-weighted average
of its sub-factor scores; the composite is the weighted sum of the group
scores:
| Group | Sub-factor scores and sub-weights (Example) | Group score | Weight | Contribution | Reason |
|---|---|---|---|---|---|
| Customer (legal entity scorecard) | Ownership 3 x 0.30; industry 2 x 0.30; PEP connection 3 x 0.20; adverse media 1 x 0.20 | 0.90 + 0.60 + 0.60 + 0.20 = 2.30 | 0.35 | 0.805 | Trust in the ownership chain (ownership 3); standard commercial sector (industry 2); BO-002 is a domestic PEP (PEP connection 3); no relevant media |
| Geography | Incorporation 1 x 0.50; counterparties 2 x 0.50 | 0.50 + 1.00 = 1.50 | 0.25 | 0.375 | Incorporated in NL; suppliers in KR and TR and holding in MT, none a score-3 or score-4 jurisdiction |
| Product and service | Highest product score = 3 | 3.00 | 0.25 | 0.750 | Trade finance and card acquiring both score 3 |
| Delivery channel | Face to face = 1 | 1.00 | 0.15 | 0.150 | Relationship opened in branch with signatory REP-002 present; remote checks used only for other individuals |
| Composite | 1.00 | 2.08 | Medium band |
Check: 0.805 + 0.375 + 0.750 + 0.150 = 2.08. Had the relationship been opened remotely with electronic identification (channel score 2), the composite would be 2.23, still Medium. The PEP match on BO-002 meets automatic trigger TRG-01 of the methodology (any PEP, domestic or foreign, among customers, beneficial owners or authorised persons), so the final rating is High with enhanced due diligence, whatever the composite score. Store the composite anyway: the EDD analyst uses it to size the enhanced measures, and model validation uses it to test the scorecard.
| Item | Value |
|---|---|
| Calculated rating | [Low / Medium / High] (Example: Medium, 2.08) |
| Automatic triggers | [List] (Example: TRG-01, PEP beneficial owner) |
| Override | [None / Up / Down, reason, approver] |
| Final rating | [Rating] (Example: High) |
| CDD level | [Simplified / Standard / Enhanced] (Example: Enhanced, EDD-2026-0311) |
9. Due diligence decision and conditions
State whether the relationship is accepted and on what conditions. If the institution cannot complete CDD, it must not establish the relationship or carry out the transaction and must terminate an existing relationship, and it must consider whether to report suspicion to the financial intelligence unit (Directive (EU) 2015/849 Art. 14(4) via national law; AMLR Art. 21 from 2027-07-10; UK MLR reg. 31). Record any refusal, because the AMLR also requires records of refused relationships to be kept (check the Art. 77 text).
| Item | Value |
|---|---|
| Decision | [Accept / Accept with conditions / Decline / Exit] |
| Rationale | [Two or three sentences] |
| Conditions | [Conditions with owners and dates] |
| Approver and authority level | [@name, role, matrix level] |
| Senior management approval (PEP or high risk) | [@name, date, reference] |
| Report to FIU considered? | [Not applicable / Yes, case reference] |
| ID | Condition | Owner | Due | Status |
|---|---|---|---|---|
| CON-001 (Example) | Obtain signed shareholder loan agreement from Strand Holding Ltd | [@rm] | 2026-10-31 | Open |
| CON-002 (Example) | No cash deposits without prior approval from compliance | [@kyc] | Ongoing | Active |
| CON-003 (Example) | Review after first six months of trade finance activity | [@rm] | 2027-04-30 | Scheduled |
Example decision: Accepted with conditions on 2026-09-30 by the head of corporate banking and approved by a member of senior management because BO-002 is a PEP. The structure is explained, ownership is verified through registers and certified documents, and expected activity reconciles to filed revenue. Enhanced monitoring applies for the duration of the PEP status and at least 12 months after it ends.
10. Ongoing monitoring and periodic review
Monitor the relationship continuously so that transactions stay consistent with what the institution knows about the customer, its business, its risk profile and, where necessary, its source of funds. Review and update the profile on a schedule set by the risk rating and whenever a trigger event occurs. From 2027-07-10 the AMLR (Art. 26) caps the interval between updates at 1 year for higher-risk customers under enhanced measures and 5 years for all others; current national law and your policy may be stricter. In the US, ongoing CDD under 31 CFR 1020.210 is risk-based; the FinCEN exceptive relief order of 2026-02-13 lets covered institutions identify beneficial owners at first account opening and then again only when facts call the information into question or risk-based monitoring requires it.
| Rating | Review frequency (Example policy) | Scope |
|---|---|---|
| High | Every 12 months | Full refresh, EDD memo update, activity review against section 6 |
| Medium | Every 36 months | Full refresh, activity review |
| Low | Every 60 months | Data refresh and screening confirmation |
Trigger events that force an early review: change of ownership or control, new PEP status, sanctions designation of a connected party, material adverse media, a suspicious activity or transaction report, activity well outside the expected profile, a request for a new higher-risk product, and a change in the customer's country links.
| ID | Date | Type | Findings | Rating after review | Reviewer |
|---|---|---|---|---|---|
| REV-001 (Example) | 2027-03-15 | Trigger: TM alert on cash deposit | Single deposit of EUR 9,500 explained as boat show takings; supported by event invoices; condition CON-002 breached and escalated | High (unchanged) | [@kyc] |
| REV-002 (Example) | 2027-09-30 | Periodic (12 months) | Volumes within 15% of profile; BO-002 still a PEP; EDD memo refreshed | High (unchanged) | [@kyc] |
Activity versus profile (complete at each review):
| Activity | Expected monthly value | Actual average | Variance | Explanation |
|---|---|---|---|---|
| Incoming SEPA (Example) | 1,450,000 | 1,610,000 | +11.0% | Seasonal peak before summer |
| Outgoing international (Example) | 1,050,000 | 1,120,000 | +6.7% | Within tolerance |
11. Records, data protection and confidentiality
Keep the profile, the evidence listed in sections 3 and 4, the screening results, the risk rating and the decision in the institution's customer records system. Retention periods apply from the end of the relationship: five years under Directive (EU) 2015/849 Art. 40 via national law (Member States may extend), five years under the AMLR Art. 77 from 2027-07-10 (counted from termination of the relationship, the occasional transaction or the refusal to enter into it), five years after account closure for US CIP identifying data and five years after the record is made for verification records, and five years under UK MLR reg. 40. Personal data collected for CDD is processed under the AML legal obligation and must not be reused for unrelated purposes without a separate legal basis.
Never disclose to the customer or third parties that a suspicious activity or transaction report has been filed or is being considered (tipping-off prohibition). Keep any reporting decisions in the restricted case file, not in this profile; record only the case reference where your procedure allows it.
| Record | System and location | Retention trigger | Retention period |
|---|---|---|---|
| This profile and versions | [CLM system] | End of relationship | [5 years or longer per national law] |
| Identity and verification evidence | [Document store] | End of relationship | [Period] |
| Screening results and dispositions | [Screening system] | End of relationship | [Period] |
| Refusal record (if declined) | [CLM system] | Date of refusal | [Period] |
12. Glossary and references
| Term | Meaning in this profile |
|---|---|
| Beneficial owner | Natural person who ultimately owns or controls the customer, or on whose behalf a transaction is carried out |
| CDD | Customer due diligence: identify, verify, understand ownership, purpose and nature, monitor |
| CIP | US Customer Identification Program under 31 CFR 1020.220 |
| EDD | Enhanced due diligence: extra measures for higher risk, PEPs and high-risk third countries |
| High-risk third country | Country identified by the European Commission (or by your national authority) as having strategic AML/CFT deficiencies |
| PEP | Politically exposed person, with family members and known close associates |
| SDD | Simplified due diligence: reduced measures where lower risk is established and the law allows |
| Senior managing official | Person recorded as beneficial owner when no owner meets the threshold, or the control person under the US rule |
| Source of funds | Origin of the money used in the relationship or transaction |
| Source of wealth | How a person built their total net worth |
References (obtain current versions):
- FATF Recommendations 10, 12, 24 and 25 (cited by number and title only).
- Directive (EU) 2015/849, as amended by Directive (EU) 2018/843, and the [Member State] transposing law.
- Regulation (EU) 2024/1624 (AMLR), OJ L, 2024-06-19, applies from 2027-07-10, EUR-Lex.
- Directive (EU) 2024/1640 (AMLD6), repealing Directive (EU) 2015/849 from 2027-07-10, EUR-Lex.
- 31 CFR 1020.220 (CIP for banks), 31 CFR 1010.230 (beneficial ownership), 31 CFR 1020.210 (AML programme for banks), eCFR.
- FinCEN order granting exceptive relief from the CDD Rule beneficial ownership requirements, 2026-02-13 (check the order text on fincen.gov).
- UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692), legislation.gov.uk.
- Related templates: Customer Risk Rating Methodology (
compliance/customer-risk-rating-methodology), EDD Memo (compliance/edd-memo), Sanctions Compliance Procedure (compliance/sanctions-compliance-procedure), AML/CFT Programme Policy (compliance/aml-cft-programme-policy), AML Business Risk Assessment (compliance/aml-business-risk-assessment), Transaction Monitoring Scenario Specification (compliance/transaction-monitoring-scenario-spec), Correspondent Banking Due Diligence (compliance/correspondent-banking-due-diligence), GDPR Records of Processing (compliance/gdpr-ropa).
Standard and licence note
Based on public law: US federal regulations in 31 CFR Chapter X (US government works) and the FinCEN order of 2026-02-13; EU legislation from EUR-Lex (Directive (EU) 2015/849 and Regulation (EU) 2024/1624), reused with acknowledgement under Commission Decision 2011/833/EU and summarised in original wording; and the UK Money Laundering Regulations 2017 cited by regulation number. FATF Recommendations and AMLA drafts are cited by number and name only; no text from them is reproduced. This template is not affiliated with or endorsed by FinCEN, the European Commission, AMLA, the FATF or any supervisor. All names, companies and figures in the examples are fictional. This template is original text written for this collection. Check the current official version of each law and your national transposition before use. Template licence: MIT.
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