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From kyc-analyst
Performs periodic customer refresh by re-verifying due diligence to detect material changes and maintain AML compliance. Triggers: time-based reviews, risk escalations, event alerts like sanctions.
npx claudepluginhub vyayasan/kyc-analystHow this skill is triggered — by the user, by Claude, or both
Slash command
/kyc-analyst:refreshThe summary Claude sees in its skill listing — used to decide when to auto-load this skill
Periodic customer review with independent re-verification to maintain ongoing due diligence compliance and detect material changes.
Activate for: KYC risk rating, customer risk classification, AML risk score, customer risk assessment, high-risk customer, risk-based approach, risk rating, customer due diligence risk score, PEP risk, geographic risk, product risk, customer risk categories. NOT for: transaction monitoring alerts (use aml-typologies), SAR/STR drafting (use aml-sar-drafting), sanctions screening (use sanctions-screening).
Guides implementation of customer identification, due diligence, beneficial ownership collection, enhanced due diligence, risk rating, and KYC monitoring under FINRA Rule 2090, CIP, and FinCEN CDD Rule.
Executes full KYC customer onboarding with mandatory Step 0 independent verification (5+1 searches), 17 stagegates, four-factor risk scoring, Excel dashboard, PDF report, and audit trail for UK/EU/US/MENA compliance.
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Periodic customer review with independent re-verification to maintain ongoing due diligence compliance and detect material changes.
Refresh is mandatory continuing monitoring required under AMLD5 (UK/EU), FinCEN CDD Rule (US), and MENA regional regulations. This skill re-runs the Step 0 onboarding verification framework to establish whether material changes have occurred and risk profile remains appropriate.
Key Principle: Refresh detects what changed, not what was previously found.
Regulatory frameworks across all jurisdictions mandate ongoing monitoring because:
Risk Emergence: Beneficial ownership, regulatory status, and threat profiles evolve. A low-risk business can pivot to high-risk sectors; transparent ownership can become hidden.
Sanction Exposure: Designation lists update monthly. Customers or their beneficial owners may become PEPs, fall under sanctions, or face criminal charges.
Adverse Media Detection: News of regulatory enforcement, criminal convictions, or corruption allegations may not appear during onboarding but emerge later.
Beneficial Ownership Verification: AMLD5 and FinCEN BOI Rule require periodic confirmation that beneficial ownership information remains accurate and complete.
See detailed regulatory requirements:
Quick Reference:
See complete trigger library: refresh-triggers.md
Types of Triggers:
Analyst Actions:
Manager Checkpoint:
Repeat exact searches from onboarding to establish fresh baseline.
Search 1: Public Profile & Business Interests
Search 2: Sanctions & Regulatory Databases
Search 3: Adverse Media Review
Search 4: Corporate Structure & Beneficial Ownership
Search 5: Financial Risk Indicators
Analyst Documentation:
Manager Checkpoint:
Compare refresh findings to original onboarding findings.
Material Changes (Automatic Escalation):
Beneficial Ownership Changes
Business Structure Changes
Regulatory Changes
Sanctions & Adverse Media Changes
Non-Material Changes (Risk Assessment Update):
Analyst Documentation:
Manager Checkpoint:
Update customer risk category based on refresh findings.
Risk Categories:
Reassessment Decision Tree:
Documentation:
Manager Checkpoint:
When to Escalate:
All material changes from Step 3 require escalation. Route to:
Escalation Urgency:
Manager Actions:
MLRO Actions:
Post-Escalation:
Output Template: Use locked template from OUTPUT_TEMPLATES/refresh-report.md
Refresh Report Contains:
Case File Updates:
Schedule Next Refresh:
Manager Final Checkpoint:
Original: Business consulting firm, LOW risk, 3-year refresh cycle Refresh finds: Company now offers crypto trading services and investment management Analysis: Business pivoted to high-risk sector (crypto) without prior disclosure Action: ESCALATE - Material change, risk reassessment required (likely HIGH)
Original: Family-owned business, clear beneficial ownership, MEDIUM risk Refresh finds: New beneficial owner acquired 30% stake via offshore entity, beneficial ownership structure now opaque Analysis: Beneficial ownership changed materially, transparency decreased Action: ESCALATE - Investigate new beneficial owner, determine if concealment patterns present
Original: Financial services firm with valid licenses, MEDIUM risk Refresh finds: Regulatory authority issued enforcement action for compliance failures; CEO charged with fraud (media alert) Analysis: Regulatory status changed; principals now under criminal investigation Action: IMMEDIATE ESCALATION - Contact MLRO for SAR evaluation and account disposition
Original: E-commerce business, transparent ownership, MEDIUM risk Refresh finds: Address moved within same city; new CFO on board; annual revenue growth documented Analysis: No material changes to beneficial ownership, business model, or regulatory status; governance updates are normal Action: CONFIRM risk category, document findings, schedule next refresh per 24-month interval
Refresh requirements vary by jurisdiction. See detailed guidance:
Multi-Jurisdictional Customers: Apply most stringent requirement. If customer operates in both UK and US, use annual refresh interval (both jurisdictions require annual for HIGH risk).
Use: /OUTPUT_TEMPLATES/refresh-report.md
Ensures consistent documentation and audit trail compliance.
Version: 1.0.0 Last Updated: 2026-02-12 Author: Vyayasan Regulated: AMLD5 (UK/EU), FinCEN CDD Rule (US), UACB/SAMA (MENA)
MCP Integration: Uses same ~~browser, ~~excel, ~~pdf connectors as onboarding workflow. See CONNECTORS.md.