kyc-customer-onboarding

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Performs customer KYC (Know Your Customer) verification and onboarding for commercial banking, including identity verification, document collection, risk assessment, sanctions screening, and account activation.

open-industry-operating-model By open-industry-operating-model schedule Updated 2/17/2026

name: kyc-customer-onboarding description: > Performs customer KYC (Know Your Customer) verification and onboarding for commercial banking, including identity verification, document collection, risk assessment, sanctions screening, and account activation. industry: financial-services sub-sector: commercial-banking function: compliance version: 1.0.0 authors:

  • name: Tyms url: https://tyms.com supported_locales:
  • UG tags:
  • kyc
  • onboarding
  • compliance
  • aml
  • customer-verification complexity: intermediate reference_framework: primary: name: "BIAN (Banking Industry Architecture Network)" version: "13.0" mapping: "Party Reference Data Management, Customer Offer, Party Authentication" secondary: name: "APQC Banking PCF" mapping: "8.1.1 Establish KYC/CDD, 8.1.2 Perform due diligence"

KYC Customer Onboarding

Purpose

This skill enables an AI agent to guide and execute the customer KYC (Know Your Customer) verification and onboarding process for commercial banking operations. It covers the end-to-end workflow from initial customer identification through document collection, risk assessment, sanctions screening, approval routing, and account activation. The skill encodes regulatory compliance requirements, reporting obligations, and audit standards that govern KYC operations across jurisdictions.

When to Use

  • New customer account opening (individual or business)
  • Periodic KYC review or re-verification when a scheduled review date is reached
  • Customer upgrade requiring enhanced verification (e.g., from basic to full account)
  • Trigger-based enhanced due diligence following a suspicious activity indicator
  • Onboarding a customer acquired through a merger, acquisition, or portfolio transfer
  • Re-onboarding a previously offboarded customer who wishes to resume the relationship

Process Overview

Step 1: Customer Identification

  • Collect customer identity information including full legal name, date of birth, nationality, and contact details
  • Determine customer type: individual, sole proprietor, corporate, NGO, trust, or other legal entity
  • Determine the required verification level based on customer type and initial risk indicators: simplified, standard, or enhanced
  • Capture the declared purpose of the account and expected transaction profile
  • Record the channel through which the application was received (branch walk-in, online, agent-assisted, referral)
  • Assign a unique application identifier and timestamp the start of the process

Step 2: Document Collection & Verification

  • Request required identity documents based on customer type and locale requirements
  • For individuals: national identity card, passport, or other government-issued photo ID
  • For businesses: certificate of incorporation, memorandum and articles of association, tax identification certificate, trading license, board resolution, and beneficial ownership declaration
  • Verify document authenticity using automated verification where available (e.g., national ID database API)
  • Cross-reference document details against the information provided in Step 1
  • Assess document quality and legibility; request resubmission with quality guidelines if documents are unreadable
  • For business accounts: trace beneficial ownership to ultimate beneficial owners holding 25% or more
  • Store verified documents in the document management system with classification tags and retention metadata

Step 3: Risk Assessment

  • Score customer risk based on the following factors: customer type, geographic location, product type, expected transaction volume, source of funds, industry or occupation, and any adverse information
  • Apply risk scoring rules to produce a numeric risk score (0-100) and a risk classification (low, medium, or high)
  • Flag high-risk indicators that require enhanced due diligence: cash-intensive businesses, cross-border activity with high-risk jurisdictions, complex ownership structures, or unusual transaction profiles
  • Determine the approval authority level required based on the risk classification: auto-approve for low risk, compliance officer for medium risk, senior compliance or committee for high risk
  • Document the risk factors and scoring rationale for the audit trail

Step 4: Screening

  • Screen the customer (and all beneficial owners for business accounts) against international sanctions lists: United Nations, OFAC, EU, and locally mandated lists
  • Check against Politically Exposed Persons (PEP) databases, including domestic and foreign PEP lists
  • Screen for adverse media coverage related to financial crime, fraud, corruption, or terrorism
  • Record each screening result individually with the list name, match confidence, and timestamp
  • For positive matches: classify as confirmed match, possible match, or false positive
  • For possible matches: queue for manual review by a compliance officer with match details

Step 5: Approval / Escalation

  • Auto-approve low-risk customers who meet all criteria: valid identity verified, documents collected, risk score below threshold, all screenings clear
  • Route medium-risk applications to a compliance officer for review with the full case file
  • Escalate high-risk applications to senior compliance officer or compliance committee with detailed risk assessment and screening results
  • For any PEP match (confirmed or possible): require human review at approver level regardless of overall risk score
  • For any confirmed sanctions match: block the application immediately and trigger a suspicious activity report
  • Record the decision (approved, rejected, escalated), the decision maker (auto-system, operator, reviewer, approver, committee), and a written rationale
  • For rejections: record the specific rejection reason and notify the customer with permitted information only

Step 6: Account Activation

  • Confirm that all KYC requirements have been satisfied: identity verified, documents collected and verified, risk assessed, screenings completed, and approval obtained
  • Activate the account in the core banking system with the appropriate account type and product configuration
  • Set transaction limits based on the assigned KYC level (simplified, standard, or enhanced)
  • Schedule the next KYC review date based on the risk classification: 12 months for high-risk, 36 months for medium-risk, 60 months for low-risk
  • Generate the compliance package containing all verification records, screening results, risk assessment, and approval documentation
  • Send account activation confirmation to the customer through their preferred communication channel

Required Inputs

Input Type Required Notes
customer_name string Yes Full legal name as it appears on identity documents
date_of_birth date Yes For individual customers; ISO 8601 format
nationality string Yes ISO 3166-1 alpha-2 country code
address object Yes Physical and/or postal address with country, city, and street
contact_phone string Yes At least one contact channel required; E.164 format preferred
contact_email string Yes At least one contact channel required
customer_type enum Yes One of: individual, sole_proprietor, corporate, ngo, trust
identity_documents file[] Yes Scans or photos of identity documents; types vary by locale overlay
source_of_funds string Yes Free-text declaration or selection from categorized list
purpose_of_account string Yes Free-text declaration or selection from categorized list
expected_monthly_turnover number No Estimated monthly transaction volume in local currency
occupation_or_industry string No For individuals: occupation; for businesses: industry sector
business_registration_docs file[] Conditional Required for business customer types; certificate, articles, etc.
beneficial_ownership object[] Conditional Required for business customers; details of all 25%+ shareholders
tax_identification_number string Conditional Required for business customers; may be required for individuals by locale
application_channel enum No One of: branch, online, agent, referral, mobile

Outputs

Output Type Description
application_id string Unique identifier assigned to this KYC application
kyc_status enum Final status: approved, pending, rejected, escalated
risk_score number (0-100) Calculated composite risk score
risk_classification enum Classification derived from risk score: low, medium, high
screening_result enum Aggregate screening outcome: clear, match, possible_match
screening_details object[] Individual results per screening list with match confidence
decision_rationale string Written explanation for the approval, rejection, or escalation decision
decision_maker object Identity and role of the person or system that made the final decision
kyc_level enum Assigned verification tier: simplified, standard, enhanced
next_review_date date Scheduled date for the next periodic KYC review
transaction_limits object Daily, monthly, and per-transaction limits based on KYC level
compliance_package object Full documentation bundle for audit: documents, screenings, risk assessment, decision record

Integration Points

System Purpose Direction
Core banking system Account creation, product assignment, limit configuration Outbound
National identity verification API Real-time identity document verification against government databases Outbound
Sanctions and PEP screening service Watchlist and PEP database screening Outbound
Adverse media screening service Automated media screening for negative news Outbound
Document management system Secure storage and retrieval of identity documents and verification records Bidirectional
Compliance case management system Escalation routing, case tracking, and workflow management Outbound
Customer communication channel Status updates, document requests, approval notifications Outbound
Regulatory reporting system Filing of suspicious activity reports and large transaction reports Outbound

Dependencies & Handoffs

Requires (inputs from other skills)

Skill Data Required Mandatory
None (entry point skill) -- --

Triggers (outputs to other skills)

Condition Triggers Skill Data Passed
Customer approved account-opening customer_id, kyc_level, risk_score, transaction_limits
Sanctions match confirmed suspicious-activity-reporting customer_id, match_details, screening_timestamp
KYC review date reached (periodic) kyc-customer-onboarding (self) customer_id, previous_kyc_date, previous_risk_score
Enhanced due diligence required enhanced-due-diligence customer_id, risk_factors, triggering_event
Business account approved beneficial-ownership-registry business_id, ownership_structure

Workflow Position

[Customer Request / Periodic Trigger]
              |
              v
   [KYC Customer Onboarding]  <-- THIS SKILL
              |
              +-- Approved -----------> [Account Opening] --> [Product Onboarding]
              |
              +-- Sanctions Match ----> [Suspicious Activity Reporting]
              |
              +-- Rejected -----------> [Rejection Notification]
              |
              +-- EDD Required -------> [Enhanced Due Diligence]
              |
              +-- Business Approved --> [Beneficial Ownership Registry]
              |
              +-- Periodic Trigger ---> [KYC Review] (self)

Roles & Permissions

Role Permissions Typical Title
operator Execute standard KYC process, collect documents, initiate automated checks, request resubmissions KYC Analyst, Customer Service Officer
reviewer Approve medium-risk applications, override auto-decisions with documented rationale, request additional information, resolve possible screening matches Compliance Officer
approver Approve high-risk applications, escalated cases, PEP and sanctions-related decisions, approve exceptions to standard process Senior Compliance Officer, Money Laundering Reporting Officer (MLRO)
auditor View-only access to all decisions, case files, reports, and the full audit trail; cannot modify any records Internal Auditor, External Auditor
admin Configure risk scoring thresholds, manage screening list subscriptions, update document acceptance rules, define approval routing logic Head of Compliance, Chief Compliance Officer

Segregation of Duties

Action Cannot Be Performed By
Approve an application The same operator who initiated or processed the case
Override a sanctions match result Anyone below Approver level
Modify risk scoring thresholds or rules Anyone below Admin level
Delete or modify audit records No one -- audit trail is immutable
Access sanctions/PEP match details Anyone without Reviewer level or above
Change document acceptance rules Anyone below Admin level

Reporting

Key Performance Indicators

KPI Description Data Source Target Frequency
First-pass approval rate Percentage of applications approved without escalation or additional information requests Step 5: Approval >= 85% Daily
Average processing time Elapsed time from application receipt to final decision start_timestamp to decision_timestamp < 24 hours Daily
Rejection rate Percentage of applications rejected Step 5: Approval Monitor (no fixed target) Weekly
Compliance exception rate Percentage of applications flagged for compliance review due to screening hits or risk triggers Step 4: Screening < 2% Daily
Document resubmission rate Percentage of applications requiring at least one document resubmission Step 2: Document Collection < 15% Weekly
PEP and sanctions hit rate Percentage of applications with positive screening matches (confirmed or possible) Step 4: Screening Monitor (no fixed target) Daily
Auto-approval rate Percentage of low-risk applications approved without human intervention Step 5: Approval >= 60% for low-risk applications Weekly
Escalation rate Percentage of applications escalated to senior compliance or committee Step 5: Approval < 5% Weekly
KYC review overdue rate Percentage of existing customers whose periodic KYC review is past the scheduled date Periodic trigger < 3% of portfolio Monthly

Data Points to Capture

Each execution of this skill should produce the following data points for reporting and analytics:

Data Point Type Captured At Used In
application_id string Process start All reports, primary key for tracking
customer_type enum Step 1: Identification Segmentation, risk distribution reports
application_channel enum Step 1: Identification Channel efficiency reports
verification_method enum (automated, manual) Step 2: Document Collection Automation efficiency reports
documents_collected_count integer Step 2: Document Collection Completeness tracking
resubmission_required boolean Step 2: Document Collection Document quality metrics
risk_score number (0-100) Step 3: Risk Assessment Risk distribution analysis
risk_classification enum (low, medium, high) Step 3: Risk Assessment Risk segmentation reports
screening_lists_checked string[] Step 4: Screening Compliance coverage reports
screening_result enum (clear, match, possible_match) Step 4: Screening Hit rate tracking
decision enum (approved, rejected, escalated) Step 5: Approval Decision distribution reports
decision_maker_type enum (auto, operator, reviewer, approver, committee) Step 5: Approval Automation tracking
rejection_reason string Step 5: Approval Rejection analysis
processing_duration_hours number Process end SLA tracking, bottleneck analysis
kyc_level_assigned enum (simplified, standard, enhanced) Step 6: Account Activation KYC level distribution

Suggested Reports

Report Frequency Audience Description
KYC Operations Dashboard Real-time Operations Manager Live pipeline view showing applications by status: pending, in-progress, approved, rejected, escalated. Includes volume trends and aging analysis.
Compliance Summary Daily Compliance Officer Exceptions, escalations, screening matches, overdue reviews, and pending compliance decisions requiring action.
Processing Efficiency Report Weekly Head of Operations Processing times by step, bottleneck identification, approval rates segmented by customer type and risk level.
Risk Distribution Report Weekly Risk Committee Distribution of risk scores across the portfolio, trend analysis over time, concentration of high-risk customers by geography and industry.
Regulatory Compliance Report Monthly / Quarterly Regulator (e.g., Bank of Uganda, Central Bank of Kenya) Suspicious transaction report counts, large transaction report counts, compliance metrics, KYC completion rates, and portfolio review status.
Automation Effectiveness Report Monthly Digital Transformation Lead Auto-approval rates, manual intervention frequency, time saved through automation, false positive rates in screening.

Alert Triggers

Alert Condition Severity Action
Processing backlog Pending applications exceed 50 AND average wait time exceeds 48 hours High Notify operations manager; consider temporary resource allocation or overtime
Compliance exception spike Exception rate exceeds 5% in a rolling 24-hour window High Notify compliance officer; investigate root cause (screening list update, new customer segment, data quality)
Sanctions match detected Any positive sanctions match (confirmed or possible) Critical Immediate compliance officer notification; block application approval; begin investigation
First-pass approval rate drop First-pass approval rate falls below 70% over a rolling 7-day period Medium Investigate potential causes: rule changes, data quality degradation, shift in customer segment
KYC reviews overdue Overdue reviews exceed 10% of the active customer portfolio High Notify compliance; prioritize the review queue; assess regulatory exposure
Auto-approval anomaly Auto-approval rate changes by more than 20 percentage points in a 24-hour period Medium Investigate rule engine behavior; check for data pipeline issues or screening service changes

Error Handling

Failure Scenarios

Scenario Handling Fallback Severity
National ID verification API unavailable Queue the application for retry (maximum 3 attempts over 24 hours) Route to manual verification using document scan and visual inspection Medium
Document quality too low for automated verification Request resubmission from the customer with specific quality guidelines (resolution, lighting, framing) Route to manual review by operator after second failed resubmission Low
Sanctions screening service timeout Block approval until screening completes; retry every 15 minutes Never approve without completed screening; notify customer of delay if wait exceeds 4 hours Critical
Customer provides conflicting information Flag the application for human review with conflict details highlighted Do not auto-resolve conflicts; require operator to contact customer for clarification Medium
Duplicate application detected Alert operator and link to the existing application Merge records if confirmed duplicate by reviewer; reject the newer application if intentional re-submission Low
Risk scoring model unavailable Use rule-based fallback scoring with conservative thresholds Route all applications to human review until model service recovers High
Core banking system down during account activation Complete all KYC steps; queue account activation for when system recovers Activate accounts in FIFO order upon recovery; notify customer of activation delay Medium
Document storage system full or unavailable Alert admin immediately; continue process using temporary local storage Do not skip document collection; migrate to permanent storage when available Medium
Customer abandons the application midway Save all progress; send a reminder after 24 hours and again after 7 days Close the incomplete application after 30 days of inactivity with a final notification Low

Critical Rules

These rules must never be violated regardless of system state, operational pressure, or override requests:

  1. Never approve without completed sanctions screening -- even if the screening service is down, the application must wait. No exception, no workaround.
  2. Never auto-approve a PEP match -- all PEP matches (confirmed or possible) require human review at approver level regardless of the overall risk score.
  3. Never delete or modify audit records -- the audit trail is immutable. No role, including admin, has permission to alter historical records.
  4. Never bypass document verification -- identity documents must be collected and verified even if the customer is known from other banking relationships.
  5. Never share screening results with the customer -- sanctions match, PEP match, and adverse media details are confidential and must not be disclosed to the applicant or any unauthorized party.
  6. Never approve an application you initiated -- the operator who processes the case cannot also be the approver; segregation of duties must be enforced at all times.

Framework Alignment

Primary Framework: BIAN (Banking Industry Architecture Network) v13.0

This skill maps to three BIAN service domains that together cover the end-to-end KYC and customer onboarding process:

BIAN Service Domain BIAN Business Area Relationship to This Skill
Party Reference Data Management Operations Primary -- governs customer identification and data collection (Steps 1-2). BIAN defines this domain as responsible for maintaining reference information about parties including individuals and organizations.
Customer Offer Sales & Service Supporting -- governs the account opening and product assignment that follows successful KYC (Step 6). BIAN defines this domain as responsible for orchestrating the evaluation and fulfillment of a customer product offer.
Party Authentication Operations Supporting -- governs the identity verification and document authentication processes (Step 2). BIAN defines this domain as responsible for authenticating the identity of a party through document and data verification.
Party Screening Risk & Compliance Supporting -- governs the sanctions and PEP screening workflow (Step 4).
Regulatory Compliance Risk & Compliance Supporting -- provides the compliance context for audit, reporting, and regulatory obligations.

What BIAN defines: BIAN provides a service-oriented architecture framework that identifies approximately 300 service domains representing discrete business capabilities. For KYC, BIAN defines the high-level service boundaries, data entities, and inter-domain relationships. BIAN tells an enterprise architect which capabilities exist and how they relate to each other at the architecture level.

What BIAN does not define: BIAN does not prescribe locale-specific regulatory requirements, accepted identity documents, risk scoring methodologies, operational KPIs, error handling procedures, audit retention periods, SLA targets, or role-based approval workflows. These are left to the implementing institution.

What OpenIOM adds: This skill fills the gap between BIAN's architectural blueprint and production operations. It provides the step-by-step operational logic, locale-specific compliance requirements (via locale overlays), risk assessment criteria, screening procedures, reporting KPIs, data classification, error handling and fallback procedures, audit event definitions, SLA expectations, role definitions with segregation of duties, and validation scenarios that a platform needs to actually execute the KYC process. Where BIAN says "Party Reference Data Management exists as a service domain," OpenIOM says "here is exactly how to collect, verify, and manage customer identity data, what can go wrong, what to measure, and what to log."

Secondary Framework: APQC Banking PCF

This skill aligns with the following APQC Banking Process Classification Framework process areas:

APQC Process ID Process Name Relationship to This Skill
8.1.1 Establish KYC / Customer Due Diligence Steps 1-3 of this skill: customer identification, document collection, and risk assessment
8.1.2 Perform due diligence Steps 3-4 of this skill: risk assessment and screening
8.1.3 Monitor ongoing customer activity Periodic review trigger that re-invokes this skill

APQC provides a hierarchical process taxonomy that complements BIAN's service-oriented view. Where BIAN organizes by capability, APQC organizes by process flow. Together they provide a complete picture: BIAN tells you which services are involved, APQC tells you where the process sits in the enterprise process hierarchy.

Notes

  • BIAN service domain mappings are based on the publicly available BIAN Service Landscape v13.0. Detailed behavioral qualifiers and service operation mappings may require BIAN membership access for full validation.
  • APQC Banking PCF process ID mappings are based on the publicly available process classification hierarchy. Detailed sub-process mappings may vary by APQC version.
  • This mapping is considered stable for the v1.0.0 release. Community feedback and formal BIAN/APQC validation are welcome to refine the alignment.

Audit Requirements

Mandatory Audit Events

Every execution of this skill must log the following events for compliance and audit purposes:

Event Data to Log Triggered At Immutable
Application received application_id, customer_id, customer_type, application_channel, receiving_operator_id, timestamp Process start Yes
Document collected application_id, document_type, document_id, collection_method (upload, scan, physical), timestamp Step 2: Document Collection Yes
Document verified application_id, document_type, verification_method (automated, manual), verification_result (pass, fail, inconclusive), verifier_id, timestamp Step 2: Document Verification Yes
Resubmission requested application_id, document_type, reason, requesting_operator_id, timestamp Step 2: Document Collection Yes
Risk score assigned application_id, risk_score, risk_classification, scoring_factors, model_version, timestamp Step 3: Risk Assessment Yes
Screening performed application_id, lists_checked, individual_results_per_list, aggregate_result, service_provider, timestamp Step 4: Screening Yes
PEP match found application_id, match_details, match_confidence, source_list, timestamp Step 4: Screening Yes
Decision made application_id, decision (approved, rejected, escalated), decision_maker_id, decision_maker_role, authority_level, rationale, timestamp Step 5: Approval Yes
Escalation triggered application_id, escalation_reason, escalated_from_role, escalated_to_role, timestamp Step 5: Approval Yes
Override applied application_id, original_decision, override_decision, override_reason, overrider_id, overrider_role, timestamp Step 5: Approval Yes
Account activated application_id, account_id, kyc_level, transaction_limits, activation_timestamp Step 6: Account Activation Yes
KYC review scheduled application_id, customer_id, next_review_date, review_trigger (risk_based, regulatory, event_based), timestamp Step 6: Account Activation Yes

Regulatory Retention Requirements

Retention periods vary by jurisdiction. The base requirement follows FATF recommendations. Locale overlays specify binding local requirements.

Jurisdiction Minimum Retention Post-Relationship Reference
Global (FATF baseline) 5 years From end of business relationship FATF Recommendation 11
Uganda 10 years From end of business relationship Anti-Money Laundering Act 2013, Section 19
Kenya 7 years From end of business relationship Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) 2009, Section 45
Tanzania 10 years From end of business relationship Anti-Money Laundering Act 2006, Section 16

Note: Locale overlays provide the definitive local requirements for each jurisdiction. The table above is indicative and must be supplemented by the applicable locale overlay.

Audit Trail Access

Role Access Level
Operator Own actions only for applications they processed
Reviewer All actions within their review scope and assigned cases
Approver All actions for applications within their approval authority
Auditor Full read access to all audit records across all applications
Admin Full read access to all audit records; cannot modify or delete
Regulator Full read access upon formal written request or regulatory examination

Data Classification

Data Sensitivity Levels

All data points handled by this skill are classified for appropriate handling by implementing platforms:

Data Point Classification Handling Requirements
customer_name PII Encrypt at rest; mask in logs and non-essential displays
date_of_birth PII Encrypt at rest; do not display in summary views
nationality PII Encrypt at rest
address PII Encrypt at rest; mask in displays showing only city/country
contact_phone PII Encrypt at rest; mask in displays (show last 4 digits only)
contact_email PII Encrypt at rest; mask in displays (show domain only)
national_id_number Sensitive PII Encrypt at rest and in transit; strict access control; never log in plaintext
identity_document_scans Sensitive PII Encrypt at rest; secure storage with access logging; retention policy applies
tax_identification_number Sensitive PII Encrypt at rest and in transit; strict access control
beneficial_ownership_details Confidential Encrypt at rest; compliance and management role access only
source_of_funds Confidential Encrypt at rest; compliance role access only
risk_score Internal Access restricted to compliance and management roles
risk_classification Internal Access restricted to compliance and management roles
risk_factors Confidential Access restricted to compliance roles; do not expose to operators
screening_result (aggregate) Confidential Audit trail required for all access; never share with the customer
pep_match_details Restricted Compliance roles only; all access logged; regulator access on formal request
sanctions_match_details Restricted Compliance roles only; all access logged; regulator access on formal request
adverse_media_results Confidential Compliance roles only; access logged
decision_rationale Internal Retain per audit requirements; accessible to reviewers and above
application_id Internal No special handling required beyond standard access controls
kyc_level Internal No special handling required beyond standard access controls
transaction_limits Internal Accessible to operations and compliance roles

Classification Definitions

Level Description Access
Public Non-sensitive information that can be shared freely All roles
Internal Business-internal information not intended for external sharing Authenticated users with an assigned role
Confidential Sensitive business information requiring access restrictions Specific roles only, as defined in the Roles & Permissions section
PII Personally Identifiable Information subject to data protection law Need-to-know basis; subject to data protection and privacy legislation
Sensitive PII High-risk personal data including national identifiers, biometrics, and document scans Strict access control; encryption mandatory at rest and in transit
Restricted Highest sensitivity level for sanctions, PEP, and law enforcement-related data Named individuals only; all access logged and auditable

Validation Scenarios

Platforms implementing this skill should verify correct behavior against the following scenarios:

# Scenario Input Profile Expected Outcome
1 Standard individual, low risk Valid national ID, employed (salaried), low-value savings account, no screening hits Auto-approved; assigned standard KYC level; standard transaction limits; next review in 60 months
2 Standard individual, medium risk Valid national ID, self-employed, medium-value business account, no screening hits Routed to compliance officer for review; standard or enhanced KYC level based on reviewer decision
3 High-risk individual Valid national ID, cash-intensive business owner, high-value account, high expected turnover Enhanced due diligence triggered; requires committee-level approval; enhanced KYC level; next review in 12 months
4 PEP detected Customer matches PEP database (domestic, high confidence) Enhanced due diligence mandatory; routed to approver level; cannot be auto-approved regardless of risk score
5 Confirmed sanctions match Positive confirmed match on OFAC or UN sanctions list Application blocked immediately; suspicious activity report filed; escalated to MLRO; customer not informed of match reason
6 Possible sanctions match (fuzzy) Partial or fuzzy name match with low confidence score Flagged for manual review by compliance officer; not auto-rejected; reviewer must confirm or clear the match
7 Expired identity document National ID card past its expiry date Resubmission requested with guidance to renew; application held but not rejected outright
8 Poor document quality Blurry scan, unreadable text, partial document Resubmission requested with specific quality guidelines; maximum 2 resubmission attempts before routing to manual review
9 Minor applicant Date of birth indicates age under 18 Redirected to minor or guardian account process; cannot proceed through standard KYC flow
10 Refugee customer Government-issued Refugee Identity Card, no national ID number Accepted under simplified KYC tier per refugee provisions in the applicable locale; reduced transaction limits applied
11 Business account, simple structure Sole proprietor, single owner, valid business registration and tax ID Standard business KYC; single beneficial owner recorded; standard processing timeline
12 Business account, complex ownership Corporate entity with 5 shareholders across 2 layers of holding companies Beneficial ownership traced to all ultimate beneficial owners; enhanced review triggered by ownership complexity
13 NGO account Valid NGO registration, multiple foreign funding sources Additional scrutiny applied per NGO regulatory provisions; enhanced due diligence on funding sources and donor relationships
14 Duplicate application Same national ID number as an existing pending application Duplicate detected; operator alerted with link to existing application; applications linked for review
15 Conflicting information Address on identity document does not match the declared address Flagged for human review; operator must contact customer to resolve the conflict before the application can proceed
16 Screening service unavailable Valid application, all documents collected, but sanctions screening API returns timeout Application queued; approval blocked until screening completes; customer notified of processing delay
17 Periodic KYC review Existing approved customer, scheduled KYC review date has been reached Re-verification process triggered; previous data pre-populated; only changes since last review require re-verification
18 Customer from high-risk geographic region Valid national ID, residential address in a border region adjacent to a conflict zone Geographic risk factor applied to risk scoring; may trigger enhanced due diligence depending on overall risk profile

Locale overlays may add additional validation scenarios specific to their jurisdiction. For example, the Uganda locale overlay includes scenarios for LC1 letters, mobile money KYC tier upgrades, and URA TIN verification failures.


SLA Expectations

Processing Time Targets

Step Target Duration Maximum Duration Notes
Step 1: Customer Identification < 5 minutes 15 minutes Primarily depends on customer input speed and channel
Step 2: Document Collection Immediate (digital upload) / 3 days (physical submission) 7 days before sending a follow-up reminder Depends on customer responsiveness and document availability
Step 2: Document Verification < 5 minutes (automated) / < 4 hours (manual) 24 hours Automated verification strongly preferred
Step 3: Risk Assessment < 1 minute (automated) 2 hours (if manual fallback is required) Should be fully automated under normal operating conditions
Step 4: Screening < 2 minutes 30 minutes Dependent on screening service availability and response time
Step 5: Approval (low-risk, auto) Immediate 4 hours Should be instant when all automated checks pass
Step 5: Approval (medium-risk) < 4 hours 24 hours Requires compliance officer review
Step 5: Approval (high-risk) < 24 hours 72 hours May require compliance committee convening
Step 6: Account Activation < 15 minutes 4 hours Post-approval; mostly automated core banking system interaction

End-to-End Targets

Scenario Target Maximum
Low-risk individual with digital documents < 30 minutes 24 hours
Medium-risk individual < 4 hours 48 hours
High-risk individual < 48 hours 5 business days
Business account (standard structure) < 24 hours 5 business days
Business account (complex ownership) < 72 hours 10 business days

SLA Breach Handling

Breach Action
Any step exceeds its maximum duration Auto-escalate to the next authority level with aging details
End-to-end processing exceeds the maximum target Alert operations manager and compliance officer; application flagged for priority processing
Customer waiting more than 48 hours without a status update Send automated status update to the customer through their preferred channel
Screening step pending for more than 30 minutes Attempt failover to backup screening service if available; alert operations if no backup

Changelog

Version Date Changes
1.0.0 2026-02-17 Initial release. Core KYC process with 6 steps. Full reporting section with 9 KPIs, 15 data points, 6 reports, and 6 alerts. Error handling with 9 failure scenarios and 6 critical rules. Audit requirements, data classification, 18 validation scenarios, SLA expectations. Framework alignment to BIAN v13.0 and APQC Banking PCF. Uganda locale overlay supported at launch.
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npx skills add https://github.com/open-industry-operating-model/skills --skill kyc-customer-onboarding
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