KYC remediation: clearing a backlog of client files
Expired documents, missing beneficial owners, risk classifications nobody revisited. We clear the backlog in your existing book at a fixed price per file — with an accountability report that explains to a supervisor exactly how it was done.
What is KYC remediation?
KYC remediation is the structured clean-up and completion of existing client files so they meet the customer due diligence policy currently in force. It concerns the book you already have: files opened under older policy, periodic reviews that slipped, or data that was never completed. It is not onboarding — there you start from zero; here you repair without damaging the relationship.
Four triggers
Supervisory findings
DNB, the AFM or the BFT has raised file quality as a finding and a remediation deadline is running. Then the approach has to be demonstrable, not just the result.
Policy tightened
You have revised the client acceptance policy but the existing book has not been brought along. Formally, it no longer complies.
Review backlog
Periodic reviews were pushed back under commercial pressure. That backlog compounds and is rarely cleared with your own people.
Acquisition or migration
You have taken on a book or migrated to a new system, and the files do not meet your standard.
How we work
| Phase | What happens | Why it works |
|---|---|---|
| 1. Baseline | A sample of 50 to 100 files to measure actual fall-out rather than estimate it. | The cost of the programme depends on the fall-out rate. You want that number before you start. |
| 2. Decision rules | Define per deficiency what counts as complete, when the client must be approached, and when a file escalates. | Without decision rules analysts judge differently and the result is not defensible. |
| 3. Execution | In batches: low risk first for pace, high risk with full four-eyes review. | You see movement in the numbers within two weeks while keeping control of the heavy files. |
| 4. Client outreach | Structured requests with a reminder schedule and a defined escalation route for non-responders. | Non-responding clients are a policy decision, not an execution problem. We put that back with you. |
| 5. Quality control | A 10% sample plus 100% four-eyes review on elevated risk. | Systematic errors get fixed in the decision rules, not file by file. |
| 6. Accountability | Report covering approach, volumes, fall-out, risk signals and reports filed. | This is the document you use to explain the programme to a supervisor. |
Why this scales
Remediation is the one compliance service where volume need not cost quality — provided quality control stays with one senior person. Here that is Tarik Binnekade, senior advisor and MLRO, who writes the decision rules, assesses escalations and signs off the samples. Execution runs on analysts under that control. You pay a senior rate for senior judgement, not for data entry.
What it costs
- Standard client file: from € 95 excluding VAT per file.
- File requiring enhanced due diligence: from € 240 excluding VAT per file.
- Project minimum: € 7,500 excluding VAT, including baseline, decision rules, quality control and final reporting.
- Baseline available separately: € 1,950 excluding VAT — so you know the cost of the whole book before committing.
Fixed price, no true-up. We carry the risk of files that turn out harder than expected; you carry the risk of clients who do not respond. We put that distinction in writing up front.
Frequently asked questions
What is KYC remediation?
KYC remediation is the structured clean-up and completion of existing client files so that they meet the customer due diligence policy currently in force. Think of expired identity documents, missing beneficial ownership records, a risk classification that was never revisited, or files opened under an older policy. It concerns the existing book, not new onboarding.
When is KYC remediation needed?
Typically for four reasons: a supervisor has raised findings on file quality; policy has been tightened and the existing book has not caught up; periodic reviews have slipped and a backlog has built; or an acquisition or migration has brought in files from another firm. The EU Anti-Money Laundering Regulation applying from 10 July 2027 is prompting many institutions as well.
How long does a remediation programme take?
It depends on volume and on how much falls out. A book of a thousand low-risk files with limited fall-out takes six to eight weeks. Where enhanced due diligence is common, or where a lot has to be requested from clients, your clients' response times set the pace — then expect three to six months.
What does KYC remediation cost per file?
We work with a fixed price per file: from € 95 excluding VAT for a standard client file and from € 240 excluding VAT for a file requiring enhanced due diligence. The project minimum is € 7,500 excluding VAT, including set-up, quality control and final reporting. You know the cost of the whole book before you commit.
Who performs quality control?
Analysts do the execution; quality control sits with our senior advisor and MLRO. As standard we sample ten per cent of completed files and apply full four-eyes review to every file with elevated risk or a change in risk classification. We report the outcome of that control, so you can demonstrate the work was tested.
Do you work under our own policy?
Yes. We remediate against your client acceptance policy and risk classification model, not against a standard of our own. If we find gaps in the policy itself during the work, we raise that separately — that is a policy question, not a file question.
What do we receive at the end?
A cleaned-up book inside your own systems, a fall-out report listing files that could not be completed and why, an overview of risk signals identified and any reports filed, and an accountability document with which you can explain to a supervisor how the remediation was carried out and tested.
Sources
- Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) — wetten.overheid.nl
- Wwft — Open Boek Toezicht, De Nederlandsche Bank
- Regulation (EU) 2024/1624 (AMLR) — EUR-Lex
- FIU-the-Netherlands
- Bureau Financieel Toezicht (BFT)
Related
Do not know how big the backlog is? That is what the baseline is for. Two weeks, fixed price, and a substantiated number instead of a gut feeling. Book a call.