KYC Screener
Run a defensible KYC/CDD review on a new or refreshed counterparty. Output is a risk-rated dossier ready for the BSA/AML officer or compliance committee — every check documented, every red flag flagged, every gap named.
When to use
- New client onboarding (corporate, partnership, fund, trust)
- Periodic refresh (typically annual or risk-based — high-risk every 12 months, standard every 24–36)
- Trigger event refresh (ownership change, sanctions update, adverse media hit, transaction pattern change)
- Vendor / counterparty due diligence on a new commercial relationship
Inputs needed (ask if missing)
- Entity legal name + jurisdiction of formation
- Entity type — corp, LLC, LP, trust, foundation, NGO
- Documents available — formation docs, certificate of good standing, ownership chart, financials, IDs of beneficial owners
- Relationship type — client, vendor, counterparty, JV partner
- Risk appetite — your firm's tolerance (conservative / standard / risk-on)
- Jurisdiction risk — countries of operation (FATF gray/black list?)
Workflow
1. Entity verification
- Confirm legal name matches registered name (state of formation registry)
- Pull formation date, current good-standing status, registered agent
- Note any name changes / mergers / dissolutions in entity history
- If foreign entity: verify with home-jurisdiction registry equivalent
2. Beneficial ownership (BO) extraction
- Walk the ownership chart down to natural persons holding ≥25% (FinCEN CTA standard) — or the threshold required by your jurisdiction
- For each BO: full legal name, DOB, residential address, citizenship, government ID
- Identify control persons (CEO/President/Managing Member) even if <25% owners
- Flag any layered structures, nominee arrangements, bearer shares
- Map any beneficial owner who is also a PEP or who appears in a sanctioned jurisdiction
3. Sanctions screening
- OFAC SDN list (US)
- OFAC Sectoral Sanctions Identifications (SSI)
- EU Consolidated Sanctions List
- UK HMT / OFSI list
- UN Security Council Consolidated List
- Country-of-formation specific lists (HKMA, MAS, etc.)
- Screen entity name + every BO + every control person
- Document fuzzy-match score, false positives, and resolution notes
4. PEP screening
- Domestic and foreign PEPs (current and former)
- Family members and close associates of PEPs
- For PEP hits: source-of-wealth and source-of-funds documentation required
- Auto-classify as Enhanced Due Diligence (EDD) if any PEP found
5. Adverse media screening
- Negative news search across major outlets (3-year lookback minimum)
- Categories to flag: financial crime, fraud, corruption, sanctions evasion, terrorism financing, narcotics, human trafficking, environmental crime
- Source the article, date it, summarize in one line
- Distinguish allegation vs. charge vs. conviction
6. Document quality grading
For each document submitted, grade A/B/C/F:
- A: Original or certified copy, current, fully legible, fully consistent
- B: Photocopy or scan, current, legible, consistent
- C: Stale (>12 months), partially legible, minor inconsistency — request refresh
- F: Inconsistent, illegible, expired, or possibly altered — REJECT and escalate
7. Risk classification
Assign overall risk: Low / Medium / High / Prohibited
- Drivers: jurisdiction, entity type, BO geography, PEP exposure, sanctions proximity, adverse media, transaction pattern, source-of-wealth clarity
- Document each driver's contribution
- Recommend ongoing monitoring frequency:
- Low: 36-month refresh
- Medium: 24-month refresh + annual screening
- High: 12-month refresh + quarterly screening + transaction monitoring escalation
- Prohibited: do not onboard / exit existing relationship per legal review
Output structure
KYC DOSSIER: [Entity Legal Name]
Reviewed: [date] | Reviewer: [name] | Refresh due: [date]
ENTITY SUMMARY
- Legal name, type, jurisdiction, formation date, good standing
- Registered address, principal place of business
- Industry / NAICS
BENEFICIAL OWNERSHIP
[Table or chart: BO name | % | role | citizenship | PEP? | sanctions? ]
SCREENING RESULTS
- Sanctions: [hit/no hit, lists checked, date]
- PEP: [hit/no hit, details]
- Adverse media: [hits with sources or "none material"]
DOCUMENT INVENTORY
[Table: doc | grade | gaps | action ]
RISK CLASSIFICATION: [LOW / MEDIUM / HIGH / PROHIBITED]
Drivers:
- [driver 1, weight, evidence]
- [driver 2, weight, evidence]
RECOMMENDATION
- Onboarding decision: APPROVE / APPROVE WITH CONDITIONS / DECLINE / ESCALATE TO COMMITTEE
- Conditions (if any): [...]
- Ongoing monitoring: [frequency + triggers]
OPEN ITEMS
- [Document gap 1]
- [Question for client 1]
Standards
- Document everything you check, even when the result is clean. A clean SDN screen with no record is not the same as no SDN screen.
- Source-of-wealth ≠ source-of-funds. PEPs require both, separately documented.
- Don't infer structure — read it. If the org chart isn't provided, request it. Don't reconstruct from financials.
- Layered structures are red flags by default. Each layer needs a business-purpose justification.
- Bearer shares and nominee directors should be treated as Prohibited unless there's a specific carve-out.
What NOT to do
- Don't auto-approve based on a clean sanctions hit alone — sanctions is one of seven dimensions
- Don't accept "we'll get you that document later" for a Medium or High risk entity — get it before approving
- Don't downgrade risk to fit a desired outcome — escalate instead
- Don't omit adverse media because it's "old news" — date it and let the committee weigh it
Adjacent CTI skills
legal:vendor-check — for the contract side of vendor onboardinglegal:compliance-check — for regulatory questions on a specific industrypdf — for parsing formation docs and IDsoperations:compliance-tracking — for ongoing monitoring cadence
Regulatory anchors (US-centric — adapt by jurisdiction)
- FinCEN CDD Final Rule (31 CFR 1010.230)
- FinCEN Corporate Transparency Act (CTA) beneficial ownership reporting
- Bank Secrecy Act (BSA) program requirements
- USA PATRIOT Act §326 (CIP)
- OFAC sanctions program — strict liability